Despite Spending Nearly $380 Million, the Internal Revenue Service Is Still Not Prepared to Enforce Compliance With the Foreign Account Tax Compliance Act

The Commissioner, Large Business and International Division, should establish follow-up procedures and initiate action to address error notices related to file submissions rejected by the ICMM to ensure that non-IGA FFIs and Model 2 IGA FFIs submit FATCA reports properly and to address unresolved record level errors to ensure that the FFIs correctly provide data for mandatory fields.

The Commissioner, Large Business and International Division, should initiate compliance efforts to address taxpayers who did not file a Form 8938 but who were reported on a Form 8966 filed by an FFI.

The Commissioner, Large Business and International Division, should, to reduce taxpayer burden in obtaining a Global Intermediary Identification Number from FFIs, add guidance to the Form 8938 instructions to inform taxpayers on how to use the FFI List Search and Download Tool on the IRS's website to search and identify an FFI's Global Intermediary Identification Number.

The Commissioner, Large Business and International Division, should initiate compliance efforts to address and correct missing or invalid TINs on Form 8966 filings by non-IGA FFIs and Model 2 IGA FFIs.

The Commissioner, Large Business and International Division, should expand compliance efforts to address and correct the invalid TINs on all Form 1042-S filings by non-IGA FFIs and Model 2 IGA FFIs.