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The Hiring Incentives to Restore Employment ("HIRE") Act of 2010 became law on March 18, 2010.  The HIRE Act included the Foreign Account Tax Compliance Act ("FATCA"), which added new sections 1471 and 1474 and 6038D to the Code.

The purpose of FATCA was to "detect, deter and discourage offshore tax evasion" by Americans and to close certain loopholes in reporting requirements that allowed U.S. persons to avoid reporting offshore assets and income.

Click here to read the ABA Section of Taxation's "Comments on the Foreign Account Tax Compliance Act ('FATCA')," co-authored by Charles Kolstad and Jeanne Newlon.