Liberty and justice for all United States persons abroad

Spritz the bowl — before you go — and no one else will ever know that your FBARs stink!

New FBAR Limits Reflecting IRS Concern on Eighth Amendment Litigation.  More poopourri:

(Spritz the bowl — before you go — and no one else will ever know that your FUBARs stink)

or, in the words of this BNA article “New constraints on penalties the IRS will impose when taxpayers don’t properly report their foreign bank accounts show agency concerns that some will argue in court that huge penalties are unconstitutional, attorneys told Bloomberg BNA.

IRS guidance limiting the penalties examiners can assert for failure to file the Report of Foreign Bank and Financial Accounts “reflects some awareness and sensitivity about the constitutional issue presented by a multi-year FBAR penalty,” ……..

“The notion that the government will exercise some administrative restraint is a good development.”

 

Let the litigations begin.

(sign up for the free trial to read the whole article)

http://www.bna.com/new-fbar-limits-n17179927429/?elq=4e5f8e82daa945c3a42c287a14e85623&elqCampaignId=882&elqaid=1571&elqat=1&elqTrackId=ef57973ec09040b1be7c66555ff36435

or shortlink

http://bit.ly/1MOU4kv

 

10 thoughts on “Spritz the bowl — before you go — and no one else will ever know that your FBARs stink!

  1. Non of these rules are binding on them. My lawyer was clear that what the IRM said didn’t matter. They could do what the hell they wanted up to the legal limits. It just makes it seem like they are treating people better. In reality you are throwing yourself at their feet and pleading for mercy.

  2. The article concludes;
    “…Some said that argument still could be made even under the new guidance, which limits the amount the government can take to 100 percent of the account”.

    Oh, so the US Treasury/IRS stealing 100 percent of a legal local post-tax non-US account IS constitutional? Or, might be slightly less unconstitutional assault and robbery – just enough confiscation to get away with?

    Sick.

  3. See “related news”;
    http://www.bna.com/us-holding-back-n17179927397/
    June 5, 2015
    ‘U.S. Holding Back on Signing OECD Tax Information Exchange Pact’

    “….Within the Group of 20 countries, which account for about 85 percent of global economic output, the U.S. is among seven jurisdictions that have not yet signed, along with Brazil, China, Japan, Russia, South Korea and Saudi Arabia, according to OECD data.”

  4. Badger – If I recall correctly the reason the US is/has not signed is that the OECD disclosure obligations are based on residence based taxation and fly in the face of CBT. The US supports the OECD program but can’t sign as it is not compatible with CBT so they go their own wat with FATCA

  5. Steve and badger,

    From earlier:

    From http://www.oecd.org/tax/transparency/AEOI-commitments.pdf, 6 March 2015, exceptionally:

    “The United States has indicated that it will be undertaking automatic information exchanges pursuant to FATCA from 2015 and has entered into intergovernmental agreements (IGAs) with other jurisdictions to do so. The Model 1A IGAs entered into by the United States acknowledge the need for the United States to achieve equivalent levels of reciprocal automatic information exchange with partner jurisdictions. They also include a political commitment to pursue the adoption of regulations and to advocate and support relevant legislation to achieve such equivalent levels of reciprocal automatic exchange.”

  6. Steve,

    Haydon Perry chimed in on an earlier post and stated that CRS is even more dangerous than FATCA. It would enable whatever system you have —- CBT, RBT, PBT, whatever.

    CRS asks every customer in the Milky Way their country of birth and city of birth.

  7. The federal reserve scam and the IRS :

    December 1913 Rockfeller Rothschield and JP Morgan convinced President Wilson to let them create the private Federal Reserve Corporation owned by them to issue US bonds. They also passed the 16th amendment to collect tax on individuals income wich is illegal according to the bill of rights of the US constitution. Not only was the 16th amendment not properly ratified, but it also stipulates “the several states” meaning Washington D.C. Guam Panama… except for the 50 states of the republic union. That’s why there is no law in the Internal Revenu Code that says an American national born in one of the 50 states owes income tax, we don’t. We are not statutary citizens of Washington D.C. gouvernment employees or green card holders who are the only ones who have to pay income tax. It’s even written on the first page of the US passport citizen/national (meaning citizen or national, in french “citoyen ou ressortissant”). That is also why there is no OMB number in the upper right hand corner of a W9 form. It’s all scam and they’ve been doing a good job of hiding the truth since WW2. But, today, thanks to FATCA, the whole world is beginning to undersand what this “New World Order” tyranny is all about. Russia, China, India, Bresil, South Africa, Saoudia Arabia and more have formed or are joining the BRIC countries to escape this scheme by no longer using the US dollar as exchange currency. The Rockfellers, Rothschields and all the rest of that private mafia corporation have lost the game. It’s only a matter of time before the US dollar collapses. That’s why they have come up with FATCA; they are getting desperate and trying to collect money by all means, even if it’s illegal. Sorry Rothschield, but you see, I don’t owe tax to private corporations like the Federal Reserve, Ford, General Motors, Google, Apple, Microsoft or Mc Donalds. I KNOW THE LAW. Just watch Karen Hudes a former IMF lawyer reveal it all on You Tube: https://www.youtube.com/watch?v=MhTvsDuP-rg

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