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Non-compliant taxpayers who are reported to the irs under FATCA may not be eligible to use the recently amended streamlined filing compliance procedures to catch up on their us filing obligations without incurring substantial penalties, since the information gleaned would presumably trigger an irs audit and investigation; under the amended rules, the initiation of a civil or criminal investigation by the IRS will preclude taxpayers from using the streamlined filing procedures. Accordingly, non-compliant taxpayers should take action to remedy their non-compliance sooner rather than later. The primary criticisms of FATCA appear to be that (1) it is unilateral, (2) it is extraterritorial, and (3) it improperly passes on the costs of detecting tax evasion— traditionally borne by government—to private parties.