All material subject to strictly enforced copyright laws. © 2022 ITR is part of the Euromoney Institutional Investor PLC group.

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 from across our site

The state secretary told the French press that the country continues to oppose pillar two’s global minimum tax rate following an Ecofin meeting last week.
This week the Biden administration has run into opposition over a proposal for a federal gas tax holiday, while the European Parliament has approved a plan for an EU carbon border mechanism.
Businesses need to improve on data management to ensure tax departments become much more integrated, according to Microsoft’s chief digital officer at a KPMG event.
Businesses must ensure any alternative benchmark rate is included in their TP studies and approved by tax authorities, as Libor for the US ends in exactly a year.
Tax directors warn that a lack of adequate planning for VAT rule changes could leave businesses exposed to regulatory errors and costly fines.
Tax professionals have urged suppliers of goods from Great Britain to Northern Ireland to pause any plans to restructure their supply chains following the NI Protocol Bill.
Tax leaders say communication with peers is important for risk management, especially on how to approach regional authorities.
Advances in compliance tools in international markets and the digitalisation of global tax administrations are increasing in-house demand for technologists.
The US fast-food company has agreed to pay €1.25 billion to settle the French investigation into its transfer pricing arrangements over allegations of tax evasion.
HM Revenue and Customs said the UK pillar two legislation will be delayed until at least December 2023, while ITR reported on a secret Netflix settlement and an IMF study on VAT cuts.
We use cookies to provide a personalized site experience.
By continuing to use & browse the site you agree to our Privacy Policy.
I agree