Foreign Account Tax Compliance Act
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Search complete. 90 mentions across 27 episodes found for "Foreign Account Tax Compliance Act".
Oct 31, 2026
speaker_0HOST
Today, we are pulling from a really detailed October 2026 article by the tax analyst Tarkoey.
speaker_0HOST
It's titled FATCA versus CRS 2.0 for U.S. persons in Europe.
speaker_0HOST
And our mission for this deep dive is to basically help you untangle your new compliance obligations.
speaker_0HOST
Because as a U.S. citizen living abroad, you are navigating two competing reporting regimes that, frankly, fundamentally do not understand each other.
speaker_0HOST
OK, let's unpack this, because before we can even look at the 2026 updates, we really need to establish the foundational asymmetry between these two systems governing your life.
speaker_0HOST
I was reading through Tarsi's breakdown, and the best way to conceptualize the difference is this.
speaker_0HOST
FATCA, which is the US law, is like a GPS tracker permanently attached to your US passport.
speaker_0HOST
It just follows you everywhere you go, regardless of where you actually live.
Bob VallierHOST
Because there's just really no effective way currently to stop that from happening.
Bob VallierHOST
One law that they tried to pass after 9-11 is called FATCA.
Bob VallierHOST
We call it fat cats.
Bob VallierHOST
And it was aimed at fat cats, right? It was aimed at the ultra wealthy who were hiding their wealth offshore
speaker_0NARRATOR
America taxes its citizens on worldwide income wherever they live.
speaker_0NARRATOR
It adds reporting on foreign accounts under the Foreign Account Tax Compliance Act, known as FATCA.
speaker_0NARRATOR
Canadian tax follows residence instead.
speaker_0NARRATOR
Once you establish non-residency, you can stop filing Canadian returns.
Virginia La Torre JekerGUEST
that you might not know about.
Virginia La Torre JekerGUEST
But it led me down this rabbit hole of understanding CRS and FATCA and what gets reported to which countries.
Virginia La Torre JekerGUEST
And it was quite interesting, John.
John RichardsonHOST
Well, it is very interesting.
Virginia La Torre JekerGUEST
They've been part of it since the beginning, July 1st, 2017.
Virginia La Torre JekerGUEST
Well,
John RichardsonHOST
actually, before we move over to FATCA, so in a general sense...
John RichardsonHOST
Once you sign on to the CRS, you can expect to receive information from the governments of other signatory countries about accounts held by your tax residents in those countries, right?
Derren JosephHOST
First thing I want to call out is AI.
Derren JosephHOST
algorithmic enforcement pincers, CRS, FATCA, and CARF.
Derren JosephHOST
I've spoken about that in multiple videos.
Derren JosephHOST
If you're not familiar with it, have a look at one of the other videos where we've discussed this.
Derren JosephHOST
Everybody's talking about AI, so we need to talk about algorithmic data matching.
Derren JosephHOST
So that information is being captured in the CRS, Automatic Exchange of Information, FATCA.
Derren JosephHOST
This is allowing revenue agencies to automatically match banks with individual and corporate returns, and therefore flag the companies that lack real footprints and proper local tax domicile.
Derren JosephHOST
So what are we doing? We're talking to our clients about four things.
Derren JosephHOST
What do I mean by that? I'm talking about offshore asset holding companies must possess genuine operational rationale, local governance, and unassailable benefit ownership documentation, real substance, the way I stand.
Derren JosephHOST
automated CRS and FATCA information chain triggers.
Derren JosephHOST
Last but not least, number three, pre-liquidity exit planning.
Derren JosephHOST
If you're planning an exit, that plan needs to be done years in advance, not months, not days, but years in advance.
David LesperanceGUEST
They don't have an IRS.
David LesperanceGUEST
They don't have FATCA.
David LesperanceGUEST
Really, the only time that's near a train you would ever need to get the tax clearance certificate is if you're going to take on some land there, and it's about $2,000 U.S. Again, that's what you're going to pay some enrolled agent to file in the U.S., I've also heard North Korea, and I have to confess, I have citizens and clients from many countries, but I've never had a North Korean client
Cory GagnonHOST
yet.
24 MINS LATER
Cory GagnonHOST
Absolutely.
Cory GagnonHOST
David, there's so much more that I'd love to ask.
Cory GagnonHOST
You mentioned around just that compliance cost and reporting, you know, you touched on FATCA and just even, you know, countries that don't don't require that level of reporting.
Cory GagnonHOST
And we've seen that globally where countries have come together and said, we're all going to force reporting and we're all going to share data.
Tom BakerHOST
But I guess what I'm asking is that from your perspective, former IRS commissioner, where do you stand on Pillar 1 and Pillar 2 and how they both interact with the U.S.?
Danny WerfelGUEST
Yeah, well, I go back in time to kind of a seminal OECD success story, which is the FATCA regime and its ability to organize and coordinate the bilateral treaties across nations to prevent tax evasion by hiding information In the US, the vernacular here is like, we're going to hide our money in a Swiss bank account.
Danny WerfelGUEST
Well, that still happens, but it's a much more difficult world to try to hide your money in a foreign bank account, whether you're trying to hide it in a US bank account or Swiss bank account or Cayman bank account.
Danny WerfelGUEST
Because the OECD had this extraordinarily successful global cooperation that led to legislation being passed in the US and the creation of a whole new regime of information sharing between nations on holdings in bank accounts for the purposes of preventing this type of tax evasion.
Thomas DubanchetGUEST
They don't understand why France keep asking them that many questions, requires them to provide that many information.
Thomas DubanchetGUEST
And so that's when I tell them, but do you know about FATCA? Because it all started there.
Thomas DubanchetGUEST
I think one, and I don't want to be racist here because as I said, I love my clients, but I think that a lot of the Americans that I'm advising, they want to transport information.
Thomas DubanchetGUEST
their own system in Europe.
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