Group Asks Treasury to Add Same-Country Exemption to FATCA Regs

October 25,2017

Assistant Secretary of the Treasury for Tax Policy David Kautter
Deputy Assistant Secretary (International Tax Affairs) Chip Harter
United States Department of the Treasury
Main Treasury
Washington, DC 20220

Dear Secretaries Kautter and Harter,

When we met recently, while not the focus of the meeting, we mentioned that American Citizens Abroad (ACA) very much hopes that the Treasury Department will decide to amend the so-called FATCA regulations to insert a Same Country Exemption.

We emphasize that SCE is supported, in addition to American Citizens Abroad, by the Federation of American Women's Clubs Overseas, Inc. (FAWCO) and the Association of Americans Resident Overseas (AARO), as well as by members of Congress (including the Congressional Americans Abroad Caucus), the National Taxpayer Advocate, the Republican Party, and Democrats Abroad. In fact, no one to our knowledge is opposed to the proposal.

The Same Country Exemption was considered by the last Administration but not embraced. There is a great deal of history surrounding this subject. ACA has advocated in favor of its adoption for a couple years. We did a good deal of research on it and dug into the details at considerable length.

Enclosed is an article — Bruce, "Treasury Passes on Same-Country Exemption. Too Bad.", TAX NOTES, March 13, 2017 — which crawls over the history and details.

ACA urges Treasury Department to reverse the prior Administration's decision on SCE and immediately to proceed with insertion of SCE in the regulations. As will be recognized, this is easily done and will quickly have a positive effect for Americans abroad.

Thank you for your consideration.

Kind regards.

Marylouise Serrato
Executive Director

Charles M. Bruce
Legal Counsel

American Citizens Abroad, Inc.
Rockville, MD

ACA is a nonprofit, nonpartisan, volunteer, membership organization. It is qualified as a tax-exempt social welfare organization (section 501(c)(4)) of the Internal Revenue Code. Alongside it is America n Citizens Abroad Global Foundation, organized as a publicly-supported charity under section 501(c)(3).