Banking executives are predicting that the majority of banks will miss the deadlines for complying with new requirements under the Foreign Account Tax Compliance Act for reporting on foreign bank accounts and assets held by U.S. taxpayers.

The controversial FATCA provisions were included by Congress in the HIRE Act of 2010, requiring foreign financial institutions to report to the Internal Revenue Service on the holdings of U.S. taxpayers. Foreign banks and governments have balked at many of the provisions, arguing that they impinge on national sovereignty, and the provisions have provoked concern among expatriate groups such as American Citizens Abroad. The IRS and the Treasury Department have tried to address some of these concerns by delaying some requirements and issuing proposed regulations (see IRS and Treasury Propose New FATCA Rules).

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