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The Foreign Account Tax Compliance Act (FATCA) was enacted in March 2010 with the primary goal of preventing tax evasion by US persons who hold accounts in foreign financial institutions (FFIs) and fail to pay US income tax on income earned in those accounts. FATCA, as broadly understood, has two main prongs: one requires reporting by FFIs and the other requires reporting by US persons. FATCA is part of a focus on offshore accounts that has also seen the Internal Revenue Service (IRS) introduce offshore voluntary disclosure programs.

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