As always, interesting commentary from Mr. Mopsick of Mopsick tax law.
Note his concluding paragraph:
FINAL FATCA FACT: With Americans abroad facing signs that read “NO AMERICAN CUSTOMERS PLEASE!” on an increasing basis, practitioners who care about this issue will continue to fight for tax justice for Americans abroad on whatever front is necessary and available. Sadly, we are seeing nothing whatsoever from the IRS that they “get it” and plan to issue even the simplest directives which show that they have no intention of surrounding Canadian nursing homes with armed special agents or more importantly that the Streamlined Program will be expanded so that it actually applies to someone, or that front line OVDP troops are permitted to actually exercise some discretion in excluding certain assets from the confiscatory FBAR penalty base.
What is clear is that FATCA has already spawned multiple years of litigation between innocent taxpayers and the IRS which will start to reach the courts in a year or two. It is not easy to pick a fight with the federal government, but given the seemingly chaotic roll of events during the last four years since FATCA was enacted, those of us who are ready to roll up our sleeves are all saying “bring it on!”
I am sure that all Americans abroad would agree with Mr. Mopsick on this. Thanks to Mr. Mopsick for taking a clear position on this!
U.S. Persons Abroad - Members of a Unique Tax, Form and Penalty Club 