Tag Archives: OVDP

FATCA – FBAR – OVDP: Comparing inside looking out (Homelanders) to outside looking in

https://twitter.com/USCitizenAbroad/status/647391630773751808

This is really worth  a watch. By the way, the prevailing view is that the Homeland does NOT care about how FATCA affects Americans abroad.

 

 

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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 in the context of the following comment to this post:

Commentary on the ‘clarifying rules’:

http://tax-expatriation.com/2014/10/14/irs-releases-clarifying-rules-for-u-s-citizens-living-outside-the-u-s-re-streamlined-filing-guidance/

“……..FAQs are all the rage these days with the IRS, as the government does not take the time or spend the resources to follow the Administrative Procedures Act or similar requirements which are required in order to issue binding rules and regulations. See a previous post regarding these requirements, specifically regarding those who renounce U.S. citizenship or abandon LPR status and have not complied with IRS Notice 2009-85. See,Does IRS Notice 2009-85 regarding expatriation have the “force of law”? Posted on April 14, 2014

Hence, these SFCP are not legally binding on the IRS and they can pick cases as they choose for audit, review and penalty assessment in any manner they think is consistent with the law. Sometimes they do it in a manner that is not consistent with the law.”………….

Americans abroad are getting special attention from the IRS

 

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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:

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@Mopsicktaxlaw takes moral high ground on taxation of #Americansabroad

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:

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#Americansabroad defend the homeland militarily and diplomatically

Robert Wood, posted a “Memorial Day Article” drawing attention to the renunciations of U.S. citizenship. The very first comment was from a Homelander who is an adherent of the “Don’t let the door hit you on the way out” principle. This particular Homelander writes:

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What US tax compliance means for #Americansabroad who have lived their whole lives in Canada

The above tweet references the following comment at the Isaac Brock Society. It explains why (if the U.S. is really serious about encouraging Americans abroad to enter the U.S. tax system, it will have to offer a serious amnesty program. This commenter is brutally honest and explains the reality of the situation very well. (Note I have added various links to the comment.)

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