If the US moved to residency based taxation would foreign banks still be required to report accounts of US citizens under FATCA?
Would these accounts still be subject to FBAR reporting and penalties even though a US expat would be free of annual tax returns? Would the banks still have the 30% withholding for errors/omissions? Would they STILL refuse US clients? (The IGA's that were signed used the term "US citizen", they did not state anything regarding the US's unique form of citizenship based taxation. (The OECD's recommended CRS only involves accounts of residents off shoring funds, not citizens living abroad. Might the US join this scheme and repeal FATCA?)