Balance of confidentiality and tax transparency in legal regulation of automatic exchange of financial account information in the United States

The subject of research, relevance. Exchange information is an important measure administrative cooperation between and among tax authorities aimed at the fight with evasion. Tax evasion a problem that has gone beyond national borders, thus individual states can’t cope it alone. In light this develop new forms such as automatic exchange information. While developing forms, should remember about balance private public interest. context looks like finding confidentiality transparency. purpose. article discusses transparency on example United States. choice States may be explained by its approach to differs from other have implemented Common Reporting Standard Mandatory Disclosure Rules. aim show what peculiarities in international regulation influence their unique effect global system rights US taxpayers. methodological basis. following scientific methods were used: comparative-legal, formal-juridical historic-legal. research was conducted compliance principles independence verification results. main results, scope application. conclusion interest reached through provisions exclusively. They use state legislation beneficial ownership lack reciprocity intergovernmental agreements implementing FATCA attract foreign investors (non-resident aliens) wishing avoid reporting under Standard. Meanwhile, acquire full financial accounts citizens resident aliens who are owners held institutions. Such affairs dangerous for effectiveness Moreover, impairs Accidental Americans permanently reside no connection except citizenship but still obligations before Internal Revenue Service. Conclusions. Automatic developed principle confidentiality. follow one same providing balance. At time taxpayers’ rights, particular Americans, protected they outweighed need or authorities.