I wanted to post an interesting FATCA comment letter below that deals with many of the issues we discuss here.
There is additional letter to from ACA. In it they acknowledge the IRS has told them that to exempt accounts of US Person’s in their countries of residence if effectively to defeat the purpose of FATCA as passed by Congress. So in some sense I don’t know where this will go. Still no comment letter yet from the Canadian Bankers Association. I get the gist though overall that FATCA will be delayed by one year (If for anything do to issues on the US side of things) and the ability to be a “recalcitrant” account holder as permitted by local law will be allowed for a significant period of time.