The conscience of a lawyer and “The FBAR Fundraiser”

Having a license to practise law (bar admission) does not a lawyer make. Admission to the Bar, gives an individual the legal right to conduct oneself as  a lawyer. A lawyer operates within a specific construct of ethics and morality. The American Bar Association Model Rules of Professional Conduct make it clear that A lawyer […]

To OVDI or not OVDI: The “In lieu of other penalties” consideration

On January 9, 2012 the IRS reopened the Offshore Voluntary Disclosure Program “OVDI”. People should enter OVDI only after an objective discussion with a lawyer who is experienced in U.S. tax compliance issues. Contrary to what at least one tax preparation firm suggests, OVDI is one of a number of compliance options. Although OVDI is […]

FBAR Penalities and The OVDI decision – A former IRS attorney talks to a seasoned “minnow”

On January 9, 2012 the IRS reopened  “OVDI” (Offshore Voluntary Disclosure Program). Some people with past compliance problems will surely consider (with the encouragement of the “cross border professionals”) whether to enter OVDI. The Isaac Brock Society issued a press release warning people to not enter OVDI without carefully considering the merits. Obviously nobody should […]

U.S. tax compliance: The costs of compliance, the costs of non-compliance, and how to choose a lawyer

The costs of coming into U.S. tax compliance and how to choose a lawyer Introduction U.S. citizenship-based taxation is bad for the U.S., bad for U.S. citizens and bad for the world. Tax compliance for U.S. citizens living outside the U.S. is very difficult. For most, U.S. citizenship has been priced out of the market. […]

OVDI Collateral Damage – U.S. Expats

Now that the September 9, 2011 deadline has passed people actually have the chance to think. It is  understood that OVDI was primarily aimed at U.S. taxpayers who were using offshore bank accounts to hide money – and evade U.S. income tax. Even the name “Offshore Voluntary Disclosure Initiative” is telling. Two points:

OVDI Collateral Damage The Story Must Be Told

Those of you reading this blog are familiar with my conviction that the U.S. has completely abandoned its historical and constitutional roots. Let me be more precise. It is the Government of the United States that is the problem. The country is run by one of two private clubs – I am referring to the […]

Compliance counseling is like a box of chocolates – “You never know what your gonna get” – Circular 230 vs. the fiduciary duty to the client

The Isaac Brock Society is becoming a interest place to “hang out”. At least this is true for many U.S. citizens living abroad who are desperately attempting to ensure that they are in U.S. tax compliance Many people are grappling with how to be compliant on a “going forward” basis. Others are trying to figure […]

Possible benefits of the coming into U.S. tax compliance through the Streamlined program?

This post originally appeared at the Isaac Brock Society. Updated November 3, 2014 – Readers are strongly encouraged to read the comments as well. One must remember that Streamlined and OVDP are programs which have been invented by the IRS. They are not found in the Internal Revenue Code. Consequently this post should be read […]

Why improving relations with #Americansabroad is difficult for the #IRS and USG

Why there is nothing the IRS can do regain the trust of #Americansabroad too bad – new #RRSP rules are well intended — U.S. Citizen Abroad (@USCitizenAbroad) October 8, 2014 This is a comment on a post at the Isaac Brock Society. @Badger Here is a post that I did in February 2012 titled: […]

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

Those who went into #OVDP treated more harshly than those who waited for #Streamlined, etc. – What's the message? — U.S. Citizen Abroad (@USCitizenAbroad) August 5, 2014 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 […]