Proposed regulations, which are due out shortly, reduce the compliance burden attached to the legislation, focus the purpose of the Act on ensuring the Treasury obtains information from financial institutions at a higher risk of non-compliance, and look to eliminate the possible conflict between FATCA and the laws of other countries, particularly relating to privacy.

“We believe that significant progress has been made over the past year, such that FATCA can in fact be implemented in a manner that is not overly burdensome, when compared to its benefits, and that it can over time serve as a complement and a catalyst to the ongoing global efforts to combat offshore tax evasion,” Emily McMahon, the Obama Administration’s chief tax policy official, told the New York State Bar Association’s Tax Section last week. “And after many months of work and a series of three preliminary notices, I am pleased to say that...