Here is a comment on an earlier post I wrote:
The IRS should be made to answer certain questions before FATCA can be enacted. Here are just a few. Other readers please add more.
1) How many Americans are affected by FATCA?
2) How many of them do the IRS consider to be criminals?
3) If there is no change in the behavior of American citizens how much extra tax will FATCA generate?
4) What percentage of Americans change their behavior if FATCA is enacted to reduce their taxes?
5) How many FFI are there in the world?
6) What is the total cost born by the FFIs to become compliant, and the annual cost thereafter?
7) How many FFIs will choose not to do business with Americans living abroad, just terminate their accounts?
In business we have failure criteria. The IRS must make a statement in advance that FATCA will be considered a failure if it fails to raise a defined amount of new taxes. Considered a failure if a certain percentage of FFIs withdraw funds from the US rather than bear the cost of compliance. Etc. etc.
For our company we are sending all the ex-pat Americans home to the US. For one reason only. FATCA.