When the US Congress passed the Foreign Account Tax Compliance Act (FATCA) in 2010 as part of its post-financial crisis efforts at economic stimulus, there was little debate or discussion about the costs or benefits of such a massive expansion of financial regulation. Since then, the UK has adopted its own ‘son of FATCA’ and France a ‘mini-FATCA’.

Elsewhere more such measures are being debated. FATCA and its progeny have spawned a raft of intergovernmental agreements (IGAs) promising transparency to tax authorities around the world. Not to be outdone, prime minster David Cameron is pushing for beneficial ownership registries for the UK, the Crown Dependencies and the Overseas Territories.