Monthly Archives: January 2012

This post has been cross posted from renounceuscitizenship.

See also:
OVDI Switcheroo: Canadian RRSP back in the penalty base
Re: OVDI Switcheroo: Canadian RRSP back in the penalty base

Those who entered OVDI understood (hopefully) that they were paying a fine based on a percentage of a base of assets. Obviously the lower the base, the lower the amount of the penalties. An interesting thread on this appeared on the Jack Townsend blog.

For Canadians who entered OVDI (for whatever reason) there has much been much concern over whether RRSPs would be part of the base for which the OVDI penalty was calculated. People have been asking: will RRSPs be included or not? Why won’t the IRS take a position? Now, what follows is just my thinking and interpretation. It is not legal advice (or any other kind of advice). But, here is how I think you should view this and the arguments you should make. Continue reading →

Note:  “ij” is a regular on Townsend’s blog.  He is, from what I gathered, originally from China (I think), spent some time in Canada, when he opened up an RRSP account, and then moved to the United States.  He entered the 2009 OVDP and has been very worried that an RRSP in Canada would be hit with a 20% fine.  To this day, the IRS has not given guidance on RRSPs.  If IJ is correct, and RRSPs will not be subject to OVDP fines, this sets a kind of precedent for all registered retirement accounts in the world, or so it could be argued, under the Equal Protection Clause.

From Just Me:

Just saw this here, and thought some Canadians might be interested.  Can’t vouch for it….

Continue reading →

Here’s the story:

Swiss Accounts, Insider Trading, Mortgages: Compliance

The date of the Bloomberg article is older, so this is most likely when Mr. Reiss was charged. He was sentenced on 11 Dec. 2012 for a 1,2+ million FBAR penalty. I could be wrong, but this appears to be the first DOJ case against a non-US Citizen working in America was charged. The rest had been mostly a few US born resident-nationals, and many foreign naturalized US citizens, some of who even earned their money abroad and paid taxes abroad, yet the IRS is desperate to get their piece.

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IRS watchdog accuses agency of “bait-and-switch”

IRS voluntary disclosure programs allowing wealthy Americans to come forward and disclose their hidden accounts

Grrrrr…. same-ole-same-ole.

Petros made some great suggestions about how to get the word out and make it stick. As I was brainstorming the other night it occurred to me that this is an election year and, if we take the right actions, we just might get some traction with some people who would otherwise happily ignore the whole business. These are 3 easy things that I have done or will do and I offer them to you as suggestions. If you have your own ideas, feel free to add them in the comments section:

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http://www.irs.gov/newsroom/article/0,,id=252036,00.html?portlet=107

It may refer to other aspects for being an innocent spouse, but we have many innocent Canadian spouses who are affected by the IRS overreach into other countries.

“The IRS is significantly changing the way we determine innocent spouse relief,” said IRS Commissioner Doug Shulman. “These improvements should dramatically enhance our process to make it fairer for victimized taxpayers facing difficult situations.”

The IRS Taxpayer advocate service came out with its annual report on the IRS and included a large section (very critical of the IRS) on FBARs, the 2009 VD program etc etc. Very scathing report, so hopefully it’ll have some impact
http://www.irs.gov/pub/irs-utl/2011_…tionalmsps.pdf

Hey folks, Just Me sent me the following video, the antidote to unemployment, FATCA, FBAR, and IRS taxes getting you down:  “Spread the sunshine….Fun fun fun” — thanks Just Me.  Life is a yellow ukelele (and I love the ukelele).

This post has been cross posted at renounceuscitizenship

The U.S. chief technology officer notes that American needs skilled immigrants. He suggests:

“Why not staple a green card to every PhD in certain fields?”

“Welcome To America” and obligations of U.S. GreenCardShip!

Continue reading →

Parts of this post are from a piece called Involuntary Citizenship – Here’s How Strange It Can Get that I wrote back in October for the Flophouse blog.

Continue reading →