The Government Accounting Office released a study to Congress acknowledgding that the FBAR and Form 8938 reporting requirements are confusing and burdensome for Americans living abroad.
A 2010 law requires Americans and foreign banks to report more information to IRS about Americans' foreign assets. Implementing the law, however, has raised some concerns.
For example, close to 75% of taxpayers reporting foreign assets to IRS also reported them separately to Treasury—indicating potential unnecessary duplication.
Also, some Americans living abroad can't get services from foreign banks that find the law too burdensome.
They recommended changing the laws to harmonize the types of assets reported and to have common minimum reporting thresholds.
They also claim that the IRS has difficulty connecting FATCA data collected from foreign banks with Form 8938 reports from taxpayers. The implementation of GIIN numbering will be improve this significantly.
Read the GAO's findings here: