How May the United States Leverage its FATCA IGA Bilateral Process to Incentivize Good Tax Administrations among the World of Black Hat and Grey Hat Governments? A Carrot & Stick Policy Proposal Academic Article uri icon


  • Professor William Byrnes examines whether it is prudent for taxpayers to trust the governments of the 117 countries that scored a fifty or below on Transparency Internationals corruption index. The complete information system invoked by the Foreign Account Tax Compliance Act (FATCA) encourages, even prolongs, the bad behavior of black hat governments by providing fuel (financial information) to feed the fire of corruption and suppression of rivals. Professor Byrnes recommends that the United States leverage a carrot-stick policy tool to incentivize bad actors to adopt best tax administration practices.

published proceedings

  • Emory International Law Review

author list (cited authors)

  • Byrnes, W.

complete list of authors

  • Byrnes, William

publication date

  • February 2017