This post is based on a more detailed post on the RenounceUSCitizenship blog. As noted by numerous bloggers, on June 3, 2014 the IRS Commissioner announced there would be modifications to the rules for allowing Americans abroad to come into tax compliance. Isaac Brock Society commentary began here. This announcement was part of a general discussion of international tax enforcement/evasion FATCA and the like. Although, I may be mistaken, I read the Commissioner’s prepared remarks to include (for the first time) a suggestion that there will be attention paid to the plight of Green Card holders with undisclosed foreign accounts. If I am correct, this is very welcome news for a group of people who have been persecuted by the U.S. Government (why would anybody want a Green Card?).
— U.S. Citizen Abroad (@USCitizenAbroad) June 4, 2014
The Commissioner’s remarks included:
Now, while the 2012 OVDP and its predecessors have operated successfully, we are currently considering making further program modifications to accomplish even more. We are considering whether our voluntary programs have been too focused on those willfully evading their tax obligations and are not accommodating enough to others who don’t necessarily need protection from criminal prosecution because their compliance failures have been of the non-willful variety. For example, we are well aware that there are many U.S. citizens who have resided abroad for many years, perhaps even the vast majority of their lives. We have been considering whether these individuals should have an opportunity to come into compliance that doesn’t involve the type of penalties that are appropriate for U.S.-resident taxpayers who were willfully hiding their investments overseas. We are also aware that there may be U.S.-resident taxpayers with unreported offshore accounts whose prior non-compliance clearly did not constitute willful tax evasion but who, to date, have not had a clear way of coming into compliance that doesn’t involve the threat of substantial penalties.
We are close to completing our deliberations on these respects and expect that we will soon put forward modifications to the programs currently in place. Our goal is to ensure we have struck the right balance between emphasis on aggressive enforcement and focus on the law-abiding instincts of most U.S. citizens who, given the proper chance, will voluntarily come into compliance and willingly remedy past mistakes. We believe that re-striking this balance between enforcement and voluntary compliance is particularly important at this point in time, given that we are nearing July 1, the effective date of FATCA. We expect we will have much more to say on these program enhancements in the very near future. So stay tuned.
The longer post from which this is excerpted is here.