Abstract
The Foreign Account Tax Compliance Act (or FATCA) has changed the face of global tax compliance. Arguably, the US government will not, on a prospective basis, need to issue requests for assistance to obtain information about its citizens’ financial foreign accounts. For the most part, FATCA mandates the disclosure of this information. As a result, many US taxpayers residing outside the United States face compliance issues, restrictions on investments, and a narrowing universe of banks and investment advisors that wish to deal with US clients. For some, the solution is to renounce their US citizenship. This article focuses on the issues that may be of interest to trustees and trust advisors in connection with the journey from voluntary compliance through expatriation.
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