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Email The Foreign Account Tax Compliance Act (“FATCA”), signed into law on March 18, 2010, was enacted to combat tax evasion by United States citizens and residents who have offshore accounts and assets. Under FATCA, beginning in 2014, the U.S. Internal Revenue Service (“IRS”) will receive annual reports (“FFI Reports”) from certain foreign financial institutions (“FFIs”) – including foreign banks and foreign investment funds – that disclose information regarding accounts and investments held or owned at the FFI by U.S. citizens and residents, including lawful permanent residents who hold U.S. “Green Cards” (“U.S. Persons”). https://www.cadwalader.com/resources/clients-friends-memos/fatca-may-open-a-pandoras-box-of-civil-and-criminal-tax-liability-for-us-persons