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by dtech 1847 days ago
I believe most EU countries aren't that interested in that information.

It's mainly because of the unique policy of the US that you have to pay taxes as a citizen no matter where you live and work. Afaik all EU countries have the policy that if you live and work in the US you only pay US taxes.

Note that it has been a nightmare for US people living in EU, especially those who emigrated decades ago or were born to an american parent but never lived in the US. US considers them citizens, but they don't have any documentation, leading to true catch-22 scenario's like not having a SSN and needing a birth certificate to get one, but not being able to request a birth certificate without a SSN. There's also stories about people not being able to rescind citizenship because they aren't in any system except for the IRS's.

4 comments

While they're less interested in that information than the US is, for the reason you explain, they're definitely still interested - many wealthy people who only pay tax in the country where they live still have substantial assets and income streams of various sorts overseas, which they must report in their local tax return.
> I believe most EU countries aren't that interested in that information.

France at least appears to be interested, requiring you to explicitly list every foreign place you can stash money on tax returns every year. If you have any kind of French rental income, no matter where you are in the world, I understand you have to declare. There is an EU directive for reciprocal information sharing and I understand it is used.

There are fines and penalties for not declaring a foreign account. The fine is not income or wealth linked, so it seems like it wouldn’t really bother anyone with the sort of wealth to benefit from not declaring; the penalty is having the stashed money treated as income for the year it is discovered, which seems like it could make certain people nervous.

> Note that it has been a nightmare for US people living in EU

It appears to make life much harder in all manner of ways. When I opened my French bank account, the forms placed a heavy emphasis on me not being a US citizen. I asked and was told that it would be much more difficult to open an account.

Does France require this information for French citizens who no longer live in France, but moved to (for example) the United States 20 years ago?

Or, as in the case of a former partner of mine: She was born in the US, from Belgian parents who worked there for a few monhts, then moved to Belgium before her first birthday. When FACTA came into play she was in her thirties, and suddenly all banks were required to submit information about her to the US. Some (Belgian) banks told her they would cancel all services as long as she remained a US citizen.

> Does France require this information for French citizens who no longer live in France, but moved to (for example) the United States 20 years ago?

No, my understanding is only if you actually have income from France – such as rental income. Income is income, and it seems fair.

I believe the US is truly exceptional with FACTA, but it’s probably only because of their current position that they are able to claim global jurisdiction over domestic legislation. If Iran passed such legislation, I doubt any banks would be allowed to comply. FACTA is often cited as a reason for people renouncing US citizenship.

Yeah, my then partner renounced US citizenship due to this.
Yeah, but that data would still be useful to track tax avoidance schemes.
Oh, they are. Maybe not in the information from the US but definitely in the information from swiss banks, there's a similar program in place.