Tax Policy
Will the IRS and G20 Countries Disagree with the WSJ Opinion Piece of Last Year-
By Patrick W. Martin
· February 27, 2014 · Updated June 3, 2026
The U.S. Foreign Account Tax Compliance Act seeks to co-opt foreign banks as long-arm enforcement agencies of the IRS.
This thoughtful article (found here) from an academic that previously appeared in the Wall Street Journal, is worth re-thinking in light of the OECD and G20 Action Plan – Base Erosion Plan.
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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