Is FATCA the new Franklin expedition?

There has been quite a bit of publicity in Canada in the past few weeks regarding a new high tech search for the ships of the doomed Franklin expedition. The location of the  HMS Erebus and the HMS Terror has been described as Canada’s greatest historical mystery.
I’m sure most of you know that Sir John Franklin set out in the mid 1840’s to find the elusive Northwest Passage. He and his crew all perished. Since then there have been many attempts to find the ships or relics of the crew and their equipment.
So, what does this have to do with FATCA? Well, one thing most researchers agree on is that Arctic explorers of the day, especially from England, totally dismissed the collective wisdom of the Inuit .Of course the Inuit had learned over many generations how to survive in the most severe conditions. But  the English saw the Inuit as primitive savages from whom nothing could be learned.
As Victoria and Christophe point out in another thread, cultural differences may have some part in the lack of flexibility of the IRS as they continue to develop FATCA regulations. Are the lawyers at the IRS frozen in time like the body of one of the  Franklin crew members, John Torrington?

FATCA has been described using several metaphors, most commonly as a train. Perhaps it should be referred to as a ship sailing in foreign waters. One of its few success stories (if you can call it that and I know many American-Swiss would not describe it that way) has been in Switzerland, a landlocked country.
Is the USS FATCA also doomed?

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