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I wouldn't have been able to mention FACTA by name, but I remember an NPR report from a couple years ago where they mentioned the IRS getting pretty short of patience with some Swiss banks for not being forthright about who their patrons are, because those patrons are now required to pay taxes on that money. If only they could do the same thing for corporations. All the big multinationals refuse to bring lots of capital to the US for fear of being taxed. There has to be a way to make it more painful not to do so. Another think Piketty points out is that this requires an international regulatory regime--one more thing that scares the sacs off of right wingers.