Reuven S. Avi-Yonah (Michigan), What Goes Around Comes Around: Why the U.S. Is Responsible for Capital Flight (and What it Can Do About It):
The U.S. learned the hard way that trying to attract foreign capital by not withholding and not collecting information is a recipe for undermining U.S. taxation of Americans. FATCA now offers a way forward to cooperate with other countries that wish to tax their wealthy residents on all income “from whatever source derived.”
