Extraterritorial U.S. citizens number up into the millions. Say 6 to 7 million. Maybe more, and likely not less.
On the compliance side, Taxpayer Advocate Service says all FBAR filing added up to 218,840 for 2008.
For 1990 a total of 180,087 IRS Form 2555 were filed from outside the United States.
The 2009 and 2011 voluntary disclosure programs reported around 33,000 disclosures by January 2012.
At a generous guess, current full compliance likely totals no more than 300,000 persons worldwide. Stay generous, go low with a pool of 6 million, and that yields a ratio of 1 in 20 compliant, or 5%.
Assume that the reported figure of 30,067 U.S. citizens reporting Canadian-earned income to the IRS in 2006 is based on something real. Multiply by 20 and that provides a common lower estimate for U.S. citizens in Canada, which is 600,000.
Then take another look at the crude Globe and Mail poll of U.S. citizen status/intention, that over half of 3233 responders intend to do nothing, and only 1 out of 5 are doing something.
A vague picture emerges. Maybe 5% of U.S. extraterritorials are OK with the IRS. Maybe 15% are worrying and/or taking specific steps. Maybe 80% just truck along in the same old limbo.
Now from the other side. The IRS says it has extracted $4.4 billion from 33,000 persons, for an average of $133,000 per person. Stay conservative, chop the potential harvest in half to 3 million, and cut the take per person to $50,000.
If this series of conjectures holds together, the IRS smells at least $150 billion more lying around out there beyond the borders — over 30 times what they have already raked in.
Even minnows can be tasty for a hungry bear?
What are the odds that this will go away?
Meanwhile, a lot of the serious money is being offshored by persons still resident in the United States.
To close with a good anecdote. A brokerage employee recently told me of a Fortune 500 CEO hoping to diversify to holdings outside the United States … a service that the Canadian financial industry is constrained to not provide.