FATCA represents the most egregious example of extra-territorial reach the U.S. has ever attempted. It will turn all the world’s banks into IRS auditors – at their own expense of course – and apply U.S. tax law on every country that allows it to happen. Its impact is so onerous that, while the Act is now legally in force, implementation has been delayed several times because the U.S. can’t produce a set of enforceable rules to make it work. Why should we care? Because the Harper government is in the middle of negotiations with the U.S. to produce an intergovernmental agreement (IGA) that would impose U.S. tax law on Canada and turn Canadian banks into IRS auditors. Should this go forward, it would represent a colossal surrender of Canadian sovereignty and likely violates the Canadian Charter of Rights and Freedoms.