Category Archives: OVDI Compliance

#OVDP #Streamlined #Quietdisclosure – Is the past a predictor of the future?

A recent post described the unequal treatment under OVDP – that is the reality that “minnows” who entered the program paid proportionately more than “whales” (who the program was presumably designed for). Thus there was clear inequity in the OVDP program itself.

But, what about those who did NOT enter OVDP? How do their fates compare with with who entered OVDP early. Do you remember Commissioner Shulman’s claims that:

Those who come in and pay earlier will pay less?

The above tweet references a post from Jack Townsend’s blog. It is a report on how the IRS is administering transitions (or lack of them) from OVDP to the new Streamlined program.

Well worth the read. It includes:

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#IRS provides penalty relief: Isolates Congress and US tax laws as the problems for #Americansabroad

 

One June 4, 2014, I wrote a post speculating that that upcoming IRS amendments to the Streamlined and OVDP programs would likely provide relief for Green Card Holders resident in the U.S. This was based on a speech given by the IRS Commissioner of June 3, 2014. As was reported in numerous blogs (and given an enthusiastic review to Mr. Mopsick), the speech included:

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@Mopsicktaxlaw takes moral high ground on taxation of #Americansabroad

Steven Mopsick has written another post on what I would call “Tax Justice For Americans Abroad”. I have commented on a number of Mopsick posts on this blog. Leaving aside Mr. Mopsick’s position on FATCA, he has consistently been opposed to citizenship-based taxation and has been a strong voice for exposing the injustice of the the FBAR Fundraiser and other IRS insanities.

The article referenced in the above tweet includes:

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For Green Card Holders with #Offshore accounts relief may be on the way

And from the IRS Commissioner …

 

On June 3, 2014 IRS Commissioner Koshinken in prepared remarks commented on matters of interest to U.S. citizens abroad including:

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#Americansabroad defend the homeland militarily and diplomatically

Robert Wood, posted a “Memorial Day Article” drawing attention to the renunciations of U.S. citizenship. The very first comment was from a Homelander who is an adherent of the “Don’t let the door hit you on the way out” principle. This particular Homelander writes:

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@JoeBwan writes about the shocking story of the #FBAR Fundraiser

 

The above tweet references an excellent series of posts written by CPA Joe Kristan about Commissioner Shulman’s tenure as IRS Commissioner and the FBAR Fundraiser. This collection of posts are among the best ever written about FBAR, OVDI and the like. Most of these were written during the “OVDI Terrorism” years of 2009 – 2012. While I’m at at it, here is some of my commentary during this period:

The taxpayer, the IRS and the “professionals” – where to go from here

(This includes links to another four posts on this topic.)

Taxpayer Advocate vs. The IRS – It’s a question of trust

(And when the IRS reintroduced the Offshore Voluntary Disclosure Program)

IRS reopens the Offshore Voluntary Disclosure Program and promises new procedures for U.S. citizens living outside the United States

It is a truly incredible story.It is an example of such incredible abuse of Americans abroad and U.S. Green Card Holders that it is deserving of a book of its own.

I have followed this story from the beginning and written a number of posts about Mr. FBAR and “The FBAR Fundraiser”.  It’s even possible that the IRS may have contributed to the failure of Americans abroad to file the FBAR.

The site of American Citizens Abroad has substantial information on the problems of FBAR and Americans abroad.

Please note that Mr. FBAR must now be filed online and only online. Mr. FBAR even has a new name. He’s called: FinCen 114.

Frankly, I don’t know how any government could do this to its citizens or lawful permanent residents.  What is wrong with these people?

 

What US tax compliance means for #Americansabroad who have lived their whole lives in Canada

The above tweet references the following comment at the Isaac Brock Society. It explains why (if the U.S. is really serious about encouraging Americans abroad to enter the U.S. tax system, it will have to offer a serious amnesty program. This commenter is brutally honest and explains the reality of the situation very well. (Note I have added various links to the comment.)

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