Michael Plowgian

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2025

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Michael Plowgian

Attorney Advisor, US Department of the Treasury

t10p-plowgian-us-treasury300.gif

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.

View the complete Global Tax 50 list

Return to the top 10

more across site & shared bottom lb ros

More from across our site

Reckitt Benckiser is to divest its Essential Home business, which includes more than 70 brands, to private equity firm Advent International
In the first of a new series of weekly opinion pieces, ITR Editor Tom Baker reflects on the OECD’s attempts to sanitise the US’s brazen pillar two negotiations
The threat of 50% tariffs on Brazilian goods coincides with new Brazilian legal powers to adopt retaliatory economic measures, local experts tell ITR
The country’s chancellor appears to have backtracked from previous pillar two scepticism; in other news, Donald Trump threatened Russia with 100% tariffs
In its latest G20 update, the OECD also revealed tense discussions with the US where the ‘significant threat’ of Section 899 was highlighted
The tax agency has increased compliance yield from wealthy individuals but cannot identify how much tax is paid by UK billionaires, the committee also claimed
Saffery cautioned that documentation requirements in new government proposals must be limited if medium-sized companies are not exempted from TP
The global minimum tax deal is not viable without US participation, Friedrich Merz has argued
Section 899 of the ‘one big beautiful’ bill would have spelled disaster for many international investors into the US, but following its shelving, attention turns to the fate of the OECD’s pillars
DLA Piper’s co-head of tax for the US and Latin America tells ITR about her fervent belief in equal access to the law, loving yoga, and paternal inspirations
Gift this article