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As background to our analysis, we will begin by identifying the purpose of FATCA, since it is important to keep that pur pose in mind in considering the various provisions discussed below. FATCA is designed to detect and deter offshore tax evasion by persons subject to us taxation. FATCA fulfills its purpose by imposing reporting, withholding, and due diligence requirements on certain financial entities regarding those entities’ us account holders and owners. To understand the harm that FATCA was designed to prevent, a brief overview of the us income tax system is in order.