Introduction – The Readers’ Digest Version
Why non-US banks, US citizens living outside the USA and the countries where they live can expect heightened FATCA enforcement in 2023: "The Carrot, The Stick And #FATCA Enforcement On #AmericansAbroad (Part 1 – Notice 2023-11)" |https://t.co/6UDsVYIxMK
— John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) January 5, 2023
This is Part 2 of a series of posts discussing the world of FATCA and how IRS Notice 2023-11 is likely to impact it. In Part 1 I described how Notice 2023-11 imposes significant additional obligations on both non-US banks and the IGA Model 1 governments. (This post will be best understood by first reading Part 1 and understanding the additional compliance burdens imposed on non-US banks as a result of Notice 2023-11.) The purpose of this post (Part 2) is to suggest that the overall context of FATCA, the FATCA IGAs and US citizenship taxation will incentivize non-US banks to purge US citizen clients. It is reasonable to conclude, that US citizen clients are a clear and present danger to their businesses.