Tag Archives: FBAR fundraiser

Snapshot in time: Eyewitness account of evolution of Schedule B and the #FBAR Form TDF 90-22.1 from 1981 to 1986

The above tweet references a fascinating discussion about Mr. #FBAR in the early years prior to the “The FBAR Fundraiser“.

Interestingly for the years 2003 to 2008 (if memory serves), IRS Publication 54 did NOT reference the FBAR requirement.

OAP says
October 11, 2016 at 4:23 pm

@heidi, @pacifica777

Now you’ve peaked my curiosity, and I’ve done a sad thing. My first filing from abroad was in 1981 and I’m sure I filed an FBAR, so I’ve dug out all the old records.

1981

A. Schedule B – It contains Part III and the question about financial accounts in a foreign country.
(I believe the instructions for Sch. B referenced FBAR.)

B. FBAR, top instructions – “This form blah, blah blah. You are not required to file a report if the aggregate value of the accounts did not exceed $1,000.”
(That’s not a typing error, it says $1,000.)

C. FBAR Line 9 – “ If you had a financial interest in one or more….accounts which are required to be reported, and the total maximum value of the accounts exceeded $10,000 during the year,….”
(Note total maximum value of the accounts, not maximum aggregate value of the accounts, and $10,000 figure.)

D. Instructions on back of FBAR – Unfortunately, for 1981 I only have the top copy and not the back.

1982
A. Schedule B – It contains Part III and the question about financial accounts in a foreign country.

B. FBAR, top instructions – Same as 1981

C. FBAR Line 9 – Same as 1981

D. Instructions on back of FBAR – Unfortunately, top copy only..

1983

A. Schedule B – It contains Part III and the question about financial accounts in a foreign country.
(For 1983, includes directions to FBAR instructions and now asks for which countries the accounts are located in.)

B. FBAR, top instructions – “This form blah, blah blah. You are not required to file a report if the aggregate value of the accounts did not exceed $5,000.”
(That’s not a typing error, it says $5,000.)

C. FBAR Line 9 – Same as 1981.

D. Instructions on back of FBAR, Who must file – Each United States Person who has financial interest in or signature authority or other authority over bank, …..or other financial accounts in a foreign country which exceeds $5,000 in aggregate value at any time during the calendar year, must report that relationship each calendar year by filing TD F 90.22.1….”
(Note $5,000 figure.)

1984

A. Schedule B – Same as 1983

B. FBAR, top instructions – “This form blah, blah blah. You are not required to file a report if the aggregate value of the accounts did not exceed $5,000.”
(That’s not a typing error, it says $5,000.)

C. FBAR Line 9 – “ If you had a financial interest in one or more….accounts which are required to be reported, and the total maximum value of the accounts exceeded $10,000 during the year,….”
(Note total maximum value of the accounts, not maximum aggregate value of the accounts.)

D. Instructions on back of FBAR, Who must file – Same as 1983. ($5,000)

1985

A. Schedule B – Same as 1983.

B. FBAR, top instructions – “This form blah, blah blah. You are not required to file a report if the aggregate value of the accounts did not exceed $5,000.”
(That’s not a typing error, it says $5,000.)

C. FBAR Line 9 – Same as 1981.

D. Instructions on back of FBAR, Who must file – Unfortunately, only top copy.

1986

A. Schedule B – Same as 1983.

B. FBAR, top instructions – “This form blah, blah blah. You are not required to file a report if the aggregate value of the accounts did not exceed $10,000.”
(It now says $10,000.)

C. FBAR Line 9 – Same as 1981.

D. Instructions on back of FBAR, Who must file – Unfortunately, I only have the top copy.

From my limited files confusion reigns. For 1983, as for 1981, (C) FBAR Line 9 mentions “total maximum value of accounts exceeded $10,000″, but the instructions on the back of the FBAR states “which exceeds $5,000 in aggregate value at any time during the calendar year”. The (B) Top instructions don’t mention $10,000 until 1986.

I’m now off to find a life.

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#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:

Continue reading

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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@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?

 

Fareed Zakaria – Immigration lessons for the U.S. from around the world – Getting them in and keeping them in!

Last night I watched Fareed Zakria host a very interesting show:

Immigration lessons for the U.S. from around the world

Mr. Zakaria – Thank’s for a job well done! I assume the Podcast will be available soon. Continue reading