What taxpayers representatives should be paying attention to in these FATCA discussions, among other things, is that the form of the FATCA submissions entitled “Schema” is a uniform computer readable report. This is the same language/requirement which is being utilized in discussions regarding intergovernmental agreements.
So effectively, in the not-too-distant future, we may be seeing foreign banks submitting their “Schema” to their government to be shared with the US and other foreign governments; which can then be used by the IRS or the other home country to match up the information in the “Schema” against that depositors local tax report!
Some of the requirement currently being discussed include that these “Schema” contain the taxpayers home country identification number. So for a US taxpayer it would contain their Social Security number.
Where that happens, tax advisers need to advise their clients that it’s no longer a question of if; rather it’s a question of when, the US and other governments are able to match the information from these intergovernmental agreements to an individual US taxpayers transcript information or other country’s tax information.
No one can tell exactly when this ability to cross match foreign information with US taxpayers transcripts will occur; however a good guess would be as soon as 3 to 5 years in the future; given all the logistics associated with such a program.