Michael Plowgian is the principal draftsman for the Foreign
Account Tax Compliance Act (FATCA), which is arguable the
biggest story in international tax of the last 12 months.
Plowgian is also the co-chairman of the Treaty Relief and
Compliance Enhancement (TRACE) project at the OECD and
represents the US on the OECD’s Working Party 10
on Exchange of Information and Tax Compliance.
Under FATCA, foreign financial institutions (FFIs) will be
required to automatically report the identity of account
holders, the beneficial owners of accounts, the balance of
accounts and any withdrawals or payments from accounts held by
US tax residents, or pay a withholding tax of 30%.
A series of intergovernmental agreements on the
implementation of FATCA is set to commit the US to reciprocal
exchange of information on partner country account holders with
US financial institutions.
The UK-US agreement has already been released and other
countries in negotiation with the US include France, Germany,
Italy, Spain, Japan and Switzerland. If other countries follow
suit - as is likely - FATCA could shape the way in which bank
account information is exchanged for tax purposes the world
over.
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