The world of international taxation becomes more transparent with every passing year. This reflects the desire of global tax authorities to achieve compliance efficiency, prevent the inappropriate avoidance of taxpaying obligations and promote equity among taxpayers. The Foreign Account Tax Compliance Act is a noteworthy evolution in U.S. tax policy with respect to so-called mobile or homeless income. It is also broadly consistent with the direction of tax policy occurring in other countries and the Organisation for Economic Cooperation and Development. While FATCA addresses U.S. accounts held for the benefit of foreign persons, the overall approach to tax base defense may find its way into the international tax reform debates that are important for the U.S. tax base.
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