Monthly Archives: February 2012

The Isaac Brock Society

The IRS uses the threat of severe FBAR penalties to frighten taxpayers into the Offshore Voluntary Disclosure initiatives (OVDI).  Thanks to a document uncovered by Showdown, we now know that the IRS is bluffing.  This is an example of bad faith.

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Tax Analysts reports that IRS Commissioner Doug Shulman will simply ignore his statutory duty to respond to a Taxpayer Advocate Directive

If this is true, it is will go down as one of the best examples of the worst judgment in the history of the IRS. You will find the complete write up on this story here:

If there is anybody who does not know the story behind this, you can either learn about it or refresh your memory in a post titled: Continue reading

The Isaac Brock Society

Petros responds to Steven J. Mopsick, 30-year IRS veteran latest comment, that some Canadians have probably found that the Overseas Voluntary Disclosure Initiative penalty of 27.5% is actually quite a good deal, since these Canadians are tax cheats and frauds. UPDATE:  Steven J. Mopsick responds with a Jack and Jill scenario of a wealthy montréalais couple with a Swiss Bank account.

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The Isaac Brock Society

Schubert receives an important clarification from Finance Minister Jim Flaherty regarding the affect that the recently-signed OECD treaty will have on the Canada-United States tax treaty, specifically regarding the protections afforded to Canadian citizens.

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The Isaac Brock Society

The Isaac Brock Society does not endorse tax professionals.  However, I have been able to provide the following content, with permission, from Moodys LLP, tax advisors blog.  It provides a useful summary of what FATCA will require the FFIs to do to detect the accounts of US persons.

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The Isaac Brock Society

This is a thought experiment regarding the Miranda Rights and how they might properly apply to OVDI and FBAR.   If a big boy says to a little boy at school, “Give me your lunch money or I will clobber you on your way home today.” The teacher sees the little boy hand the money over to be the big boy. The big boy says to the teacher: “He gave it to me voluntarily.”

UPDATE:  Steven J. Mopsick, 30 year IRS Veteran has responded.

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The Isaac Brock Society

Renounce tweeted this evening about Congressman Tierney’s proposal to do away with the Foreign Income Exclusion.  That caught my eye, and so I inquired of Andy Sundberg and ACA.   If you wonder why the Tax Code is over 72,000 pages, after you read this information he sent me, you will wonder no more..

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