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Michael Plowgian

Attorney Advisor, US Department of the Treasury

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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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