This past weekend, the powerful and influential Taxation Section of the American Bar Association met in Boston and to no one’s surprise, the offshore voluntary disclosure initiative was a front and center focus which practitioners used to voice concern over the issues...
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Stacking Up Penalties Is Nothing New For The IRS
A reader posted the following on another web site asking for my input, my response is below his post: “IRC code 6677 title 26” Published on August 28, 2012 by mach73 in Issues regarding US persons abroad. “Hoping Mr. Mopsick will chime in on this, but it seems every...
Phasing in FATCA: How Will Foreign Banks Determine Which Of Their Customers Have To Be Reported To The IRS?
FATCA was enacted over two years ago but apart from the requirement to register all “specified foreign financial assets” with the IRS on last year’s (2011) tax returns, the punishing 30% withholding provisions have yet to kick in for nonparticipating foreign financial...
Understanding The FATCA Regulations: The Search For Suspected Americans With Offshore Accounts
Recently, a for profit promoter in London was able to convince the IRS Office of Chief Counsel to allow two of its very qualified senior attorneys to speak via satellite link to a withholding congress group about the new FATCA Regulations. This presentation has been...
IRS Changes to OIC: Much Ado About Nothing
In May of this year the IRS announced some changes to the Offer in Compromise (OIC) program. The IRS changes include: 1. How they calculate future income; 2. Allowing certain student loan payments; 3. Allowing taxpayers payments for delinquent state or local taxes; and 4. Expanding the allowable living expense standard. I see some practitioners touting these changes as though…
The Unintended Consequences Of FATCA And The Bank Secrecy Act
How To Make The Government Listen To The Plight Of Americans Abroad And Recent Immigrants To The United States- What Works; What Doesnt One of the hottest issues in tax compliance today is how to make the U.S. government address the unintended consequences of the...
Tax Justice II: No FBAR Penalties For Otherwise Compliant Recent Immigrants To The United States
We recently blogged and published an article about Tax Justice for Americans abroad with little or no economic connection to the United States. In our article, we argued that paying a 27.5% tribute to the IRS under the voluntary disclosure program made no sense for...
Tax Justice for Americans Abroad
My recently published article in Tax Notes Today The potential for IRS overreaching in its enforcement of the Bank Secrecy Act (FBAR's) and FATCA has created a firestorm of fear and anxiety in the world-wide American expatriate community. The IRS has done a good job...
Whoever Said The IRS Lacked Common Sense?
New Filing Procedure For Americans Abroad; Too Little, But Not Too Late On June 26, 2012, the IRS announced a new filing compliance procedure for non-resident U.S taxpayers. The procedure provides that current non-residents including dual citizens, who have not filed...
Another FATCA Red Herring: A Good Way To Defeat FATCA Is To Defeat Obama In November
This past week, the Isaac Brock Society published another interesting thread which basically asked if Obama deserves to be re-elected in light of FATCA, OVDI, and FBAR's. Here are some slightly edited comments Imposted: (You can see the origional post here) The title...