@all, the article below just appeared in the Hamilton Spectator re ‘voluntary disclosures’ . with a glancing mention of FATCA. The authors are from KPMG.
Tue Mar 27 2012
by Jeffrey Brown and Elena Hanson
(“Jeffrey Brown is a partner and Elena Hanson is a senior manager with KPMG’s US and Cross-Border Tax Group in Hamilton.”)
“Americans in Canada beware of IRS bloodhounds”
“Whether they know it or not, most of the roughly one million “United States persons” who reside in Canada remain subject to US income tax. US persons include US citizens, green card holders and even some “accidental Americans” who don’t realize they are subject to US tax. Non-compliance with US tax laws among US persons in Canada remains widespread, according to analysis by accounting firm KPMG, and has recently become subject to intense enforcement by the Internal Revenue Service (IRS). While the time has come for US persons to “get back into the US tax system”, there are alternative approaches to remedy past non-compliance……………”
“…….US persons abroad can favourably correct past non-compliance but the window of opportunity for doing so is closing. For example, beginning in 2014, a new US law mandates that financial institutions outside of the US disclose to the IRS all accounts held by US persons. To achieve the best possible outcome, non-compliant US persons should review their situation with qualified US tax advisers to map out their best approach for becoming and remaining compliant sooner rather than later.”
It only alludes to FATCA: “After 2010, a foreign account disclosure similar to and in addition to FBAR is a part of the US income tax return….”