In May of 2021, the United States Department of Treasury (“Treasury”) introduced its revenue proposals for the 2022 fiscal year. One of the proposals that garnered significant attention was the Comprehensive Financial Account Reporting to Improve Tax Compliance; under this proposal, financial institutions will be required to report to the Treasury the total amount of inflow and outflow on bank, loan, and investment accounts for accounts that hold at least $600 a year. Since its introduction and after serious political push-back, this amount has since been increased to accounts that hold at least $10,000 a year.

If the reporting requirement is implemented, the Biden Administration proposes to raise the Internal Revenue Service (“IRS”) funding by $80 billion to finance the cost of additional auditors and equipment. However, the Biden Administration, with the proposal’s implementation, expects a payoff of $460 billion over ten years in additional revenue. Although this proposal is intended at limiting wealth tax evasion, this proposal misses the mark. Specifically, it does not adequately address businesses that are able to cheat tax codes by stretching the current law, and instead scrutinizes small businesses and individuals while it exponentially increases the personal data held by the Treasury.