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:
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!
Interesting FATCA and tax compliance post from Mr. Mopsick which includes:
For both Americans abroad and recent immigrants: Millions of people are agonizing over the question, “Should I just blow it off or do I really need to take some action?” The answer is easy: Whether you take action or not is all based on your personal tolerance level for risk and uncertainty. It is your decision to make. Many people are totally comfortable with the idea that they will never get caught violating the tax laws by not reporting foreign income and accounts or for some reason don’t care if they do get caught. This is because it is one thing for the IRS to compute a tax due and owing from a delinquent taxpayer, but the IRS is years away from routine collection in the ordinary course of delinquent taxes from Americans overseas, provided there are no periodic or regular payments like Social Security payments or pension payments leaving the US for accounts abroad.
Leaving one with the question for Americans abroad:
Is it more dangerous to be IN tax compliance or NOT in tax compliance?
Time will tell. If Mr. Mopsick is correct in his analysis, this suggests those NOT in tax compliance have time to respond to their situation and NOT react!