Originally Posted by christmasoompa

When the Streamlined Foreign Offshore Procedures were expanded in 2014, FATCA was still relatively new. Many Americans living abroad had little understanding of the complex U.S. international reporting rules, and the IRS recognized that widespread noncompliance often resulted from ignorance rather than intentional misconduct.

The environment today is very different. Foreign financial institutions routinely inquire about U.S. tax status (generally require account holders to complete a Form W-9 or W-8BEN). FATCA reporting has become a normal part of international banking. The IRS receives vast amounts of information from foreign financial institutions each year.

The IRS may reasonably conclude that taxpayers have now had ample opportunity to become aware of their filing obligations and that extraordinary administrative relief is no longer needed to the same extent. Whether that conclusion accurately reflects the experiences of Americans abroad is another question. Tax practitioners continue to encounter taxpayers who first discover their filing obligations only after a foreign bank requests U.S. tax documentation or when they begin the process of relinquishing or renouncing U.S. citizenship.