I got this email today, and I could not resist the temptation to put it up here. It is yet another example of sausage making in DC, and why a 72,500 page tax code is going to soon be over 73,000 pages…
The author was Bruce Krasting. He has a good blog you might want to add to your list.
It starts off like this..
This week our leaders in D.C. extended the payroll tax deduction for another ten months. The new law also extends Unemployment Benefits, and it allows for a continuation of the old payouts to Doctors for Medicare reimbursements. The cost of the legislation is $110b for the rest of the year. There are some minor offsets to this expense in out years. (We will never see those offsets.)
This legislation should have been easy to draft because it is was just an extension of what had been agreed to, two months ago. But that’s not the case. H.R. 3630 is 386 pages long. The Bill includes some interesting things:
Read the rest of it on his blog… Asset and Means testing is starting, plus other interesting items.
Note: 4:31 PM…This blog post just disappeared. I will keep watching for it, and put it back up when it becomes available, or will summarize what he put in his email about H.R. 3630.
So Mr Mopsick..
Didn’t I tell you so! I rest my case..
http://www.rothcpa.com/taxupdates.php
IRS COMMISSIONER SHULMAN: YOU OBEY THE LAW. ME, THAT’S DIFFERENT.
February 20, 2012
The IRS hasn’t been known for sympathy for inadvertent violators of the foreign account reporting rules. Americans inheriting foreign property from distant relatives, young Americans who moved abroad to start a career, children born in the U.S. who have lived abroad since infancy — all face stern wrath, and big fines, for not filing foreign financial account disclosures that they had no idea existed.
You would think that a Commissioner so stern about punishing foot-faults would be extra careful about obeying the rules itself, if he had a smidgen of shame or self-awareness. Apparently not.
Tax Analysts reports that IRS Commissioner Doug Shulman will simply ignore his statutory duty to respond to a Taxpayer Advocate Directive on abuses of offshore taxpayers in the Offshore Voluntary Disclosure program. From the story
Here you can afford an account, so sign in and read it…. Would be very interested in your justification for this action, which I told you he would do…
http://services.taxanalysts.com/taxbase/tbnews.nsf/Go?OpenAgent&2012+TNT+34-6
IRS Commissioner Douglas Shulman has no plans to respond in writing to National Taxpayer Advocate Nina Olson’s taxpayer advocate directive (TAD) on the IRS offshore voluntary disclosure program (OVDP) despite a statutory requirement that taxpayer advocate recommendations be responded to within 90 days, Olson said February 17.
According to Olson, who spoke at the Individual and Family Taxation session of the American Bar Association Section of Taxation meeting in San Diego, Shulman told her that section 7803(c), which requires the commissioner to formally respond to any taxpayer advocate recommendation within three months of its submission, applies only to the taxpayer advocate’s annual report and not to recommendations made through TADs or taxpayer assistance orders (TAOs).
How convenient for him. Let’s see what Section 7803(c) says:
(3) Responsibilities of Commissioner
The Commissioner shall establish procedures requiring a formal response to all recommendations submitted to the Commissioner by the National Taxpayer Advocate within 3 months after submission to the Commissioner.
That’s “all recommendations.” Not “all recommendations submitted in the annual report of the Taxpayer Advocate.” Not “all recommendations under this Section.” Just “all recommendations.” If there was a 50% annual penalty assessed on the balance of the Commissioner’s bank and retirement accounts for failing to respond on time — the same penalty that he is gleefully assessing on offshore account non-reporters — I bet he would have responded. After all, unlike the unwitting victims of the offshore compliance jaywalker hunt, it’s clear the Commissioner is well aware of this requirement and the LAW…
Stephen, I think I have heard you say, “We are a nation of laws”, right? So, one law for the Commissioner, and another for all of us?
And you wonder why we are angry and cynical? The IRS sure makes it hard for us to be otherwise.
@Saddened – I’m also working on getting citizenship where I live. I’m thinking it will take 24 months to get here.
I’m not scared of being stateless because if I need to travel, I can go to the Federal Police and get a “Passport for Foreigners” and then travel.
@all
Just found this on the net.
http://www.rothcpa.com/taxupdates.php
Scroll down to:
“Is now the time to dump overdue FBARs on the IRS?”
@ UncleTell, thanks for listing the rothcpa link above. I’ve responded to his tax news update with a comment of my own. I strongly believe that we–all of us who read this site–should make an effort to respond to any online blog, news article, etc. that addresses our situation. Call it public relations for our cause, but each time we respond in a clear and compelling fashion, we might help penetrate the ignorance a little stateside and help change a few minds. In my view, this is as much a political battle as it is a public relations battle–and any political change begins with a change in perception. If nothing better, it lets off some steam.
@Brash
Sorry, I can’t take all the credit 🙂
Just Me posted the link first, I just noted the video with Clint Eastwood further down on the web page.
@just me: please see my comment on another thread about the Comish vs the NTA. I would respectfully suggest that the Commisioner’s failure to respond to the NTA is hardly a good example or proof that we are not really a nation of laws or that Mr. Shulman is a bad guy.
I never personally met the man but I have seen some of his predessesors and their staffs and the kind of people they surrounded themselves with, up close on a daily basis.
I can say that the Comissioner of Internal Revenue and all the people around him work really hard and long hours. Twelve hour days are routine and every night they take home papers to read so that they can understand the people who maybe talking at them the next day. Almost everyone at that level has a law degree, but these people went the finest schools where they distinguished themselves with their scholarship and achievement. Also they all tend to be very conservative in their social and moral habits. Not necessarily conservative politically, but very modest when it comes to drinking, socializing, and who they hang around with in their very brief “off” hours.
These are people who mix it up with the best and brightest people at the top of other agencies, almost all of who are at the top of their game. They are challenged on their positions and reasoning and no one ever survives in Washington if they think they are going to get by on the basis of bull shit, not at that level of government. They don’t flaunt or break the law either. They take their jobs very seriously and in their minds they are performing a valuable and hopefully appreciated public service.
I am not so much “defending my buddies at the IRS” as I am reacting to words people actually put down on paper which reflect a profound misunderstanding if not plain ignorance of what actually goes on at a place like the IRS and how the government actually works.
Respectfully submitted,
30 Year IRS Vet
@steven
“……I am reacting to words people actually put down on paper which reflect a profound misunderstanding if not plain ignorance of what actually goes on at a place like the IRS and how the government actually works. ”
If this is truly your honest feeling than there must be some “reasonable cause” why we are so misunderstanding. Maybe some of these “….Not necessarily conservative politically, but very modest when it comes to drinking, socializing, and who they hang around with in their very brief “off” hours. ” people just need a swift kick in the ass. Like my grandfather used to say! They should get up off their cosy leather chair and proactively DO SOMETHING ABOUT IT!!!!
Is it that hard or even unheard of an announcement or a video with Mr. Schulman saying something like this:
“To all my fellow US taxable persons residing abroad, who haven’t been filing for any reason what so ever and believe they might be in trouble with the IRS I am telling right you now LOUD AND CLEAR please do absolutely nothing until we here at the IRS get our act in together and make a PUBLIC ANNOUNCEMENT on this web site and in the international media that we can supply you with ALL the information you will need to either correct the past in such way that ALL parties involved can be able to accept or put the past behind us and work together for a clearer future.“
Why, why , why in the name of God should something like this be SO hard to do??
The IRS is quick to swing a sledgehammer and making threats, but too coward to admit to the fact that they just might have made a serious mistake but are willing to come out and openly admit it, apologize and promise a clear and fair solution to the problem.
@Steven ” Almost everyone at that level has a law degree, but these people went the finest schools where they distinguished themselves with their scholarship and achievement.”
That is my problem. So they assume I have the same level of intelligence to fully understand the tax code. Failure is unthinkable.
This country is run by a bunch of lawyers who went finest schools.
Your screwed, because you are stupid
@Stephen,
Thanks again for your comments. I have not seen what you have posted on another thread. I will search for it tonight, but it would help if you give me a thread title to look for. There are getting to be a lot of threads, as you have noted. Thanks.
Well, here goes another attempt at communication. What can one say back to you, to make a connection? I am not trying to be argumentative for argument sake. Again, I truly respect the fact that you engage with us here, it takes cojones. I hope you don’t take this personally as I am really trying not to insult you, but sometimes your words have a bit of an elitist air about them to my ears. Maybe I am being too sensitive, and it is not intentional, but rather comes from years of dealing with peers who see the world as you do.
With all due respect, however, do you think I fell off a turnip truck yesterday? Do you think I am incapable of understanding or commiserating with the life of a DC IRS agency head?
Let’s say you are right about Shulman, and I can certainly concede to what you say. He is a good guy, works hard and long hours, surrounds himself with the “best and the brightest”, conducts a very conservative social life, takes his job seriously, is skilled, is dedicated and is constantly working to be at the top of his game. He doesn’t flaunt the law, he just parses it. He probably loves his wife, children, goes to church and prays to a god for forgiveness on Sundays. He is an exemplary patriotic American.
And so what? Isn’t that what we should expect from someone working at the level in government who is supposed to be our servant and is paid some of the highest wages in the nation?
Do you think that description of hard work and dedication is the sole providence of “the best and the brightest” of legal minds in DC? I may not have the legal pedigree, or have gone to the finest schools, but that work ethic and dedication description with conservative social life could have described me to a T in my business life. My off time was/is very brief much to my wife’s protest. In fact it still describes me, in retirement, as evidenced by the fact that here I am late at night pounding out a response to you, in an attempt to connect.
You know, there is book by David Halberstand, called the “Best and the Brightest,” and what did that get us? The disaster called Vietnam, so as a cautionary tale, let’s not worship too much at that alter.
Another disaster is in the works, in my opinion, and it is done in the name of good intentions created by those “best and the brightest” you say I don’t understand.
Look, I have been involved with Senators and staff to get special legislation added as an amendment to must pass bills, so have been around the block a bit. I have a very close friend in DC who currently works as lobbyist / VP of Government Affairs for a Big Corporation you would know, and when I hear of the some of the most crazy regulations imaginable that come out of the bureaucracies there, I have to wonder what is happening inside those bubbles of the “best and the brightest” that is creating these “dumb and the dumbest” of policies.
Personally, more than “best and brightest” I am looking for folks that are working “smart and the smartest” as well as hard, and have their ear to the ground to understand the impacts of their policies on ordinary lives, and not just acting arbitrarily without discretion imposing directives from on high. I am looking for a little grace, humility, fairness and common sense to go along with those legal pedigrees of the “best and the brightest.”
Shulman has obviously had his attorneys review the NTA statutes, which I have looked at too. They parsed the language to mean that he doesn’t have to formally respond. I think I can see how they got there. Let’s say for argument sake he doesn’t have a technical “legal” requirement to respond “formally” (shall we parse formally?) to a TAD, as it is not fully codified. But….why not do it anyway? What is he afraid of? Why does he just run to the rule book to find a way not to do something, rather than just face the directive on its merits? Is it sooo hard to admit a mistake, or does he think that the harm he has been creating around the world in exchange for cump change compared to our deficit spending in the past 3 years is as a great success that his press releases claim?
Never mind that it takes 2 years to process someone, and that there is no statistical basis provided for evaluating success except sheer exclamations that would be laughed down by analyst if he had to do the equivalent of Corporate quarterly earnings conference call. Where are the “Best and Brightest” statisticians that can lay out the evidence of success? How about showing us just one meaningful stat, like the Whale to Minnow ratio inside the OVDP program. How about a parsing of the new revenues claimed to show back income tax collected versus the “in lieu of” penalties levied. How about some compliance percentages before and after all these efforts as measured by FBARs submitted versus the estimate of how many FBARs you expect should be filed. I may not be the smartest, but I know something about unit costs and measures and how everything he has proclaimed to date is metrically speaking,Crap. Yes, that is an accounting technical term!
Maybe this is something the ‘best and brightest” first year MBA student could work on to help us “ordinary and average” out here understand just how GREAT all these programs are working out, statistically speaking.
What is so hard about saying….
“Hey, maybe we got that OVDP program slightly wrong. Maybe we misplaced the emphasis in our eagerness to get those UBS type cheats. Maybe we should find a more expeditious way to administratively handle minnows who are just trying to be compliant. Let’s find a way to make it quicker and less administratively burdensome. Let’s try some of that free enterprise “lean processing” and see if we can make some incremental improvements. Maybe we should respond to Nina in the affirmative. Hey team, let’s do the right thing and make some adjustments as she suggests?”
Is that so tough, oh dear Leader?
In response to your comment that you are “reacting to words people actually put down on paper which reflect a profound misunderstanding if not plain ignorance of what actually goes on at a place like the IRS and how the government actually works.”
With all due respect, we have clear evidence of how Government works, and it isn’t pretty.
I would say, I am “reacting to a Commissioner who seems to have a profound misunderstanding if not plain ignorance of the negative impact of his policies on average expats, dual citizens and US persons around the world, or how normal middle class people lives actually work.”
Though out the OVDP, I tried real hard to understand the IRS policy makers and examiners. I tried to communicate early and often. I have tried to put myself in their shoes, understand their perspective, commiserate with the problems they have administering a complex program. I have empathized with their challenges, and what did that get me?
Nothing.
As a Leader of the IRS, it is time for him to start doing his job and try to understand US and appreciate how his policies impact US, instead of visa versa. In this he is failing, in-spite of his hard work and his legions of “best and brightest” that surround him. He is supposed to be our servant, not the other way around.
It wasn’t until I found another agency, called the TAS, did I find a responsive group of professionals who included some of the “best and brightest” combined with common sense and equal dedication who GOT IT. They restored my faith in the idea that government can do the right thing and serve its citizens in a fair and just manner.
However, until I see some evidence of that from Shulam, I will listen to the words of wiser person who said. “By their works ye shall know them”. Well, I can see the works, and I think I know them very very well.
Respectfully submitted..
Just Me, Marvin Van Horn
@UcleTell
Amen!
@Steven: I appreciate your effort in presenting IRS side of this story. I believe you are not defending IRS but trying to rationalize some of their actions.
Having said that, I have hard time accepting/understanding the very smart and hard working executives at IRS applying one size fits all FBAR penalties to tax cheats (i) who are living in the USA and intentionally hiding money in tax heavens and (2) duel-citizens living in their adopted countries and owe no taxes.
“An injured friend is the bitterest of foes.” Thomas Jefferson
The IRS deliberately and carelessly causing injury to expats, who have been strongest supporters of the USA. If six million expats and many more millions of green card holders end-up bitter and betrayed by their own country, it is going to cost the USA huge in long term. For example, I am in the process of start a new company in the USA. But now I am afraid to do so. I can’t believe IRS any more. Taxes in my country is higher but in the USA the problem is too much regulation, complex tax code and huge life altering penalties for innocent mistakes (no tax liabilities, but penalties for not filing a form). In my country I can afford to hire a lawyer to defend myself, but I can’t do that in the USA. I have top-notch lawyers and judges in my family to defend me.
Also millions of expats try to avoid the USA. For example, each visitor to USA spends few thousand on hotels and rental cars etc. The lost revenues would be in billions. Many rich Asians wanted to buy houses in the USA, since they are very cheap and good diversification of their assets. But now advisers are strongly discouraging them. In fact, few months back I recommended to many of my friends to buy a house and I also wanted to buy a house. At that time, I didn’t know about FBAR jihad. Thanks to good advise of a tax expert they didn’t buy houses, otherwise I would be very sorry for causing injury to many good friends.
Please understand why people in this forum are very angry. They are all law abiding and strongly believe they are living honest lives. Now it is a shock to them that they were branded as criminals and tax cheats. All of them want to come clean, if a fair opportunity is given to them. By pursuing this jihad against innocent dual-citizens, from the comments in this forum, I feel, many of them decided never to enter the USA instead of paying FBAR penalties. Any person with criminal intent real don’t care until he is caught, since he is well informed and try to stay one step ahead of IRS.
Most expats didn’t know they are committing a criminal act, so they innocently walked in to a trap for crooks. For example, it is so easy to hide money in developing countries like India for crooks. No one opens account in high tax countries such as Canada or India to avoid taxes. The IRS must give automatic FBAR penalty waiver for people who are living in high-tax countries and for the accounts in the country where they are living with families and paying taxes on the income, and (2) dual-citizens living in their adopted countries and owe no taxes.
Here is an piece which deals with how to measure pretentiousness:
http://www.slate.com/articles/life/low_concept/2012/01/calvin_trillin_offers_a_new_way_of_measuring_pretentiousness.html
@All: this is very sad; I am trying to paint a picture of what life is like not only in the corridors of power on Constitution Avenue in Washington but I would assume as well in Ottawa, London, and Brussels yet some people see “pretentiousness.”
I can only hope that the many thousands of people who are reading this blog but choose not to post, really do “get” what I have been trying to say.
Talk about argumentum ad hominem!!
“An ad hominem (Latin for “to the man” or “to the person”), short for argumentum ad hominem, is an attempt to negate the truth of a claim by pointing out a negative characteristic or belief of the person supporting it.[1] Ad hominem reasoning is normally described as a logical fallacy.[2][3][4]–“from Wikipedia
30 Year IRS Vet
Well Stephen it is sad. I for one, and not trying to negate the truth of your claim using argumentum ad hominem. I think that might be a bit of a straw dog. A way to dismiss the crux of the discussion? Not sure. I am not impugning your good intentions or those in power who make these policy decisions. I get your point. But, I am trying to see if you get my point about the unintended and negative impacts of bad policy, and apparently not. So maybe I give up too.
I have conceded a lot to you, but maybe it is in the lawyers DNA not to concede anything back.
I think the readers of this blog get the issues. But then I could be wrong.
Hang in there, two way communication that listens to each other’s POV is hard, I will give you that, but I think I get yours, and I am not sure yet you get ours.
I guess we will agree to disagree. No hard feelings.
Young John F. Kennedy’s application letter for Harvard
My academic accomplishments will never match up to the Harvard man who is now running the White House. I am a moose eater from the Northwest. I admit that I am not particularly impressed by your claim that these folks running Washington are the brightest and the best and that they went to the finest schools. That’s not ad hominem. It is is just a gut level feeling that stupid is what stupid does.
@Steven: I am usually highly skeptical of the holier than thou folks who paint themselves as having fine morals. Perhaps the most recent example of that is Newt Gingrich, who lead the charge to impeach Bill Clinton for lying about having oral sex with an intern. Mr. Gingrich did not tell us that, at the time, he was having an affair with a congressional aide and had asked his second wife, who had just been diagnosed with MS for an “open marriage.” This, of course, was after leaving his first wife for his second wife when the first wife had cancer. Gingrich, who now wants to be the Prez, declares himself to be the defender of family values.
Are these the morals you’re talking about in Washington? Give me a break!
What about Timothy Geithner’s morals? What about his income tax evasion?
I haven’t seen any morals coming out of Washington for a very long time. Perhaps Jimmy Carter, but I’m sure somone can uncover some skeletons in his closet if they look hard enough (the same is probably true fo most of us.)
How is it moral or even respectful to lump law-abiding American citizens and former American citizens together as “tax cheats, tax evaders and traitors.” Does anyone care how that is affecting us? The answer is clear: No, they don’t. Any moral person wouldn’t be so callous.
On the topic of well educated lawyers, the Canadian Charter and Human Rights lawyer TIger, Somefugl and I have contacted about FATCA has handled landmark cases. He has law degrees from both a prestigious Canadian university and Harvard Law School.
Although he is on vacation now, he personally e-mailed me within hours of his office receiving my inquiry to say he is “very interested in this matter.” He asked if we could wait until after his return from vacation on March 6. One of his associates phoned a few minutes ago to confirm with me that we felt we could wait until his return.
I’m not prepared to share any more information about this in a public forum, but I want to assure you there are well educated, experienced Canadian lawyers who can go head to head with American ones.
With all that said, Steven, I am glad you’re hanging in with us!
@Steven: Hear, Hear to comments from many above.
I do realize well-educated and moral lawyers don’t usually handle simple tasks well. They are much better at writing 72,000 page Tax Codes, which no one–including IRS Director, accountants and tax lawyers–can understand. But, for the benefit of us simple, less educated, less moral beings, it would help if you would answer UncleTell’s relatively simple question:
Why, why , why in the name of God should something like this be SO hard to do??
@geeez, You mention that about the only Americans living abroad who are not having trobuble with FBARs, etc. are those retirees who only have US bank accounts. You have to be careful to not let the bank know you live outside of the US, by having your bank statement sent to a relative or friend who lives in and has a US mailing address. Under the Know your Client provision of the Patriot Act, it is not illegal for a US bank to have accounts with non-US residents. However, unless it is an account with a relative large balance, US banks are very likely to close it down. It costs them a lot of vigilance money to be absolutely sure that persons outside the US are not using these accounts for illegal money-laundering purposes. I am aware of several US citizens who have lived abroad for many years who have had their US bank accounts closed down because they did not have a US address as their “addresss of record” with the bank.
Retirees living abroad can withdraw funds from ATMs back home as long as they stilll are able to maintain US bank accounts, but because they are US citizens they may well be turned down in obtaining a foreign bank account where they reside abroad. Because of FATCA, many foreign banks will not touch a US citizen with a 10-foot pole.
@Roger: I don’t know if you can answer this question, but I will ask it anyway. My sister and I have power of attorney for my mother if she should be unable to make her own financial or personal care decision. While frail in body Mom is feisty in spirit and strong in mind.
My mother and sister both live in U.S. I am a Canadian citizen. If the day should come that neither my mother nor my sister were able to look after her finances, could this cause problems for her or for me?
As you know, I have believed I am NOT a US citizen since 1973. Information and a letter from Ladybug posted today confirms what I and others were told. When I agreed to be my mother’s POA, I didn’t think about whether it could cause problems for her (or for me). I don’t want to do anything to tell her about this whole debacle because if my mother doesn’t have something to worry about, she’ll find something to worry about! She’s 89 and I don’t want to do anything to upset her. But, if this issue could place either her or me in jeopardy, we need to deal with it sooner rather than later.
I asked Mom not to make me Executor of her will for fear that would be very complicated on
a cross-border basis, so my sister took on that role.
I promise neither my mother nor I are money launderers. Mom doesn’t even do her own laundry anymore. She has an aide who comes in once a week to help her.
I suspect there are probably others with parents in US with similar issues.
@Roger, yeah, I forgot about that one. The Patriot Act makes that hard already. I have had the “legal departments” of some companies call me before to ask “What are you DOING in Brazil?” It’s kind of annoying really. I’m not doing anything illegal, or wrong, or else I would be locked up here. So why do they give me the 3rd degree? I know… the “Patriot Act”.
Just today, after playing tennis for 2 hours, I went by the driving schooll to ask about get a motorcycle qualification on my drivers license. The girl remembered me and told me that my Brazilian drivers license was expired and needed to be renewed within 30 days or I would lose it. I had totally forgotten about this! So tomorrow I have to take my license there with the $50 renewal fee (in Reais of course) and give it to her to give to the “despachante” to get my license renewed for me.
The point to mentioning this is that NOTHING in my life involves the US, but they seem to want to make my life difficult, even though I’m FAR from sipping martinis on the beach. My wife said today: “Eu vou marcar com a Polícai Federal de uma vez”. That means we have nearly all of the documents that I need to naturalize :-). Bye bye US.
I’m a little disappointed with the way this has to be. My parents and cousins and everyone else I know in the US is NOT irrational. So why does the government have to be this way?
@geez: According to Steven, the government is “this way” because it is run by fine, upstanding , intelligent, moral and very well-educated lawyers.
@geeez, Things are a different in Brazil today, but we really loved the 7 years we lived there. And we would probably still be there today if it had not been for the Tax Reform Act of 1976 that, the day it was signed by President Ford, made my combined US plus Brazilan income tax 81% more than any non-American in Brazil with my exact same income and family status. I had almost completed the building of a new house in Barra da Tijuca on the south side of Rio. We never got to live in it, but I did complete it after returning to the US, rented it and then sold it. In those days with tight foreign exchange controls it was not easy to get my money out, but with patience and inginuity I finally did.
My rental income from that house was of course subject to both Brazilian and US tax and my US tax return was audited by the IRS to confirm the cost basis upon which I was claming depreciation. It was well documented.
@Blaze, not being an attorney or really familiar with these things I don’t really have the answers to these questions. I know you need to be very careful for understandable reasons, so I suggest that you discuss this with an attorney who is well versed in these cross-border matters. I have a power of attorney from my wife which she signed when she was still able to do so, but we live together in the US so my experiences would not fit your situation. You would not want to walk into a tax trap.
My wife has Alzheimer’s and is no longer able to make decisions or take care of herself, even though physically she is still in pretty good shape.
I hope Mr. Doug Shulman or IRS explains his reason for applying same FBAR punishment both to (i) intentional tax cheats who hide ill-gotten money in off-shore tax heavens and (ii) innocent duel-citizens caught in a wide trap of off-shore accounts opened in their own countries of living.
It looks like Mr. Doug Shulman deliberately avoiding this question, because he has been refusing to respond to TAD issued by Miss. Nina Olson. Mr. Doug Shulman is causing irreparable damage to the lives of six million honest ex-pats, which results in huge damage to US economy in long term as they mistrust USA and become defensive and avoid US assets.
If IRS has a valid reason, why IRS is not responding to Miss. Nina Olson? Why IRS is deliberately breaking a law?
@Steven, if you were Mr. Doug Shulman, what would be your response to Miss. Nina Olson? Please keep in mind, Mr. Doug Shulman’s response might be used in one of the many FBAR/SwissBank litigation now pending in courts.
Accepting Miss. Nina Olson TAD will force IRS to return billions to innocent expats, who were trapped in the wide-net. Providing reasons for rejecting Miss. Nina Olson TAD would harm the pending cases. So IRS deliberately maintaining silence.
@Steven –
Your description of how the IRS works at the higher policy levels – bright, hardworking policy wonks fascinated by accounting – makes a certain amount of sense. These are the people who devised excruciatingly complicated tax regimes for people with basically simple financial lives. These are people who look at the Byzantine paperwork that faces people with some modest Canadian retirement savings defined as PFICs and think it’s perfectly reasonable, These are people who look at someone who has self-incorporated in Ontario and think it’s perfectly reasonable for them to spend 35 hours every year completing Form 5471.
Look, if the US had a reasonable tax system that could actually be complied with from outside the country by real people with real lives, jobs and noisy small children and limited time I WOULD NEVER HAVE RENOUNCED.
Our Canadian taxes take ONE EVENING A YEAR. We don’t need an accountant, and we certainly don’t need a tax lawyer. That’s how reasonable countries organize things.
I’m sorry the IRS is run by bright people from the Ivy League who really enjoy the intellectual theory of the whole thing. I wish it was run by practical people whose goal was to have a practical system that could actually be complied with.