FATCA - Chapter 4, FBAR and Title 31, Tax Policy

Foreign Government Criticizes U.S. Government for NOT Providing FATCA IGA Information on Their Taxpayers with U.S. Accounts

By · December 14, 2015 · Updated June 3, 2026

This news is ironic.  The U.S. government has chastised various banks and governments around the world since 2009 for not providing financial information on U.S citizens (USCs) and other U.S. taxpayers regarding their foreign bank and financial accounts.   See, How Congressional Hearings (Particularly In the Senate) Drive IRS and Justice Department Behavior, posted Sept 8, 2014.  FBAR 114 electronic

Now, it is foreign governments’ turn, to criticize the U.S. Treasury and IRS for not keeping up with its promises to provide U.S. financial and bank information on taxpayers of their countries pursuant to all of the FATCA Intergovernmental Government Agreements (IGAs) that were pushed so hard by U.S. Treasury. See, FATCA IGA with Hong Kong Signed: U.S. Citizens and Lawful Permanent Residents Residing in or Around Hong Kong Need to Know, posted on Nov. 17, 2014.

The Commissioner of the Mexican IRS (SAT – Servicio de Administración Tributaria (SAT)), Mr. Aristóteles Núñez Sánchez just announced that the U.S. government is not holding up its side of the bargain under the U.S.-Mexico IGA.  See, the Dec. 12, 2015 article en the national Mexican newspaper, El Universal, EU incumple entrega de informacion: SAT: Mexico ha hecho su parte, asegura Aristóteles Núñez

The article, which is in Spanish, explains that Mexico has complied with its obligations under the IGA by providing detailed information about U.S. taxpayers with accounts in Mexican financial institutions to the U.S. government.  However, the U.S. government has not complied with its side of the bargain.  The news report says no specific details were provided by Mr. Núñez about what type of information was provided.

Patrick W. Martin

Patrick W. Martin

U.S. International Tax Lawyer · Shareholder, Chamberlain Hrdlicka

Patrick W. Martin is a U.S. tax lawyer licensed in California, Texas, and Washington, D.C., with 32+ years advising on the tax consequences of renouncing U.S. citizenship or abandoning lawful permanent residency. He served as lead counsel in Aroeste v. United States, the landmark federal case on green card holders, tax treaties, and the exit tax. Best Lawyers in America® (Tax Law), 2015–2025.

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