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?).
For Green Card Holders with #Offshore accounts relief may be on the way http://t.co/Gde57eQBVx
— 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.
Care to venture how the IRS under Streamlined might respond to FBAR’s equaling a couple of hundred grand one year and then $1.5M the next?
Pingback: Green Card Program 2014
The U.S. politicians have succeeded beyond the wildest imagination of Karl Marx. Our sales and service people have been driven home. Our export market has been wrecked. Our trade deficit has sky rocketed. We have the fewest people working as a percentage of the population in our history. The middle Class has almost disappeared. More people are getting food stamps and taxpayer assistance than ever. Those who vote for a living outnumber those who work for a living. Politicians look for a campaign contribution before they vote to extend a tax break for the business or person they slipped it into a bill for the last time and we have class warfare like never before. Only 36% of those working have a job or business that consumers are willing to pay for the goods or service and the taxes paid by that 36% pays the salary of the 64% who have a governmental paycheck coming in. (Borrowed money that we can never repay also pays some of the 64%) The bills will come due and we can’t pay.
If every newspaper and TV station did nothing but advocate using the communist manifesto as their guide, they couldn’t be more effective in assisting the destruction of the last best hope for mankind.
If the government withdrew the payments we’d have rioting and the current president could declare Martial Law and cancel elections. Marx would love it.
My wife’s experience with the Streamlined Process (after opting out of the 2011 OVDI) was good – that is she ended up being declared low risk and did not face any penalties.. This was helped by the helpful, professional agent she had.
If the IRS comes out with a reasonable process to deal once and for all, with the ‘minnows’ I would not bet on them getting it right. It took them 6 months to clarify some parts of the Streamlined Process, and even when my wife got into it the agent needed to consult with other officials on how to answer some of the questions properly. When she opted out from the OVDI she still got a standard printout warning her of possible penalties. Of the thousand of pages of IRS documentation I have read there are often parts poorly written and confusing. To expect something different with a new program is a stretch!
And, what will it cost in professional US tax law and/or accounting help? Will anyone be able to figure out anything by themselves? Some have the luxury or some extra $$$ to throw at these monstrosity programs — and reality is that some just don’t!!
Pingback: More U.S. Taxpayers Expected to Report Undisclosed Foreign Bank Accounts - LawFuel