Nigel Johnston has made a real comprehensive assessment of what it will take to implement FATCA, obviously something Congress didn’t bother with. When delving more deeply into its workings, there are more questions than answers and a growing frustration with the lack of guidance the US is providing for such a huge undertaking. Do we need any more proof how misguided and irresponsible FATCA is, especially with the current time constraints? I read elsewhere that to do a good job would take five to seven years, and the US wants commitment by 2013! Those 30% withholdings probably look pretty appetizing right now as they are almost within grasp.