Category Archives: Issues regarding US persons abroad

Penalty abatement, reasonable cause, and the facts that support reasonable cause

The Isaac Brock is a wonderful forum for discussion. It is also a wonderful resource. A resource that will alert you to issues that may be relevant to your compliance. Some readers are clearly grappling with the best way to come into compliance . This involves tax or  information returns or both. The Isaac Brock Society has been fortunate to have had contributions from two lawyers: Roy Berg in Alberta and Steven Mopsick in California. Their thoughts and contributions have been greatly appreciated.

In the December 2011 FS the IRS made it clear that penalties could be abated if the taxpayer were able to show “reasonable cause”. Continue reading →

 
“Five to six million Americans living abroad, along with 39 million immigrants in the U.S., should theoretically be filing an FBAR. Yet in 2009, only 534,043 were filed, according to the Treasury Inspector General for Tax Administration.”

This nugget extracted from:

http://frontpagemag.com/2012/02/06/the-1-percent-exodus/

Among extraterritorials and immigrants to the United States …
100 to 1? 50 to 1? Who knows?

In cosmology, scale shifts to order of magnitude. Here on a chunk of planet Earth, navigation falls back on magnitude of disorder.
 

http://www.reuters.com/article/2012/02/06/financial-regulation-et-idUSL2E8D68E220120206

I thought the headline in the Reuters article I linked to below was good for a blog post heading. A couple of quotes:

The United States is coming to be seen as a global threat, acting unilaterally with aggressive new market rules that critics say will hurt U.S. firms, foreign banks, and international markets in one swoop.

The new buzzword in the financial world is “extraterritoriality”, or ET. The idea that a government can exercise its authority beyond its borders.

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See the first installment of this series:  Sweeter than Honey I:  Introduction

Petros continues the series of posts comparing the law code of ancient Israel, the United States Constitution, and the Internal Revenue Code.  This post considers what the law implies about the purpose of man.

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X marks the spot. The spot where the ex has to take a stand. Perhaps even the spot where the ex eventually gets buried.

The Isaac Brock narratives turn on many different themes. How the ex came to be — and how the ex came to be even more subjected than the peculiar majority that remains encircled by the geographic borders that define such a singular nation as the United States.

The foremost word in this tangle is expatriation. The IRS offers Guidance for Expatriates Under Section 877A and Expatriation Tax. That is the you-can’t-go-home-again (if home it ever was) expatriation of an irrevocably redefined status.

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ACA recommendations for fundamental reform of U.S. tax laws affecting bona fide overseas residents has been posted on its website.   They will be discussing these in DC this week.

http://www.aca.ch/joomla/index.php?option=com_content&task=view&id=504&Itemid=97

Cover sheet is here…

Position paper _ No. 1: An alternative to citizenship-based taxation with major economic advantages for the United States

Position paper _No. 2: Eleven proposals for tax reforms required and applicable within the framework of citizenship-based taxation.

Comments of support can be emailed to info.aca@gmail.com

Also, I will be sure to point ACA Directors attention to this web site for any comments that might be made here.

I wanted to make this a separate post so that it doesn’t get lost in the long line of comments.”

First, thanks to Mr. Mopsick for willing to post on this blog. He is the only lawyer (as far as I know) who has written complete posts. I thank him for sharing his perspectives. After reading the comments: it is worth remembering that his central message is that he is willing to talk to people – everybody has a different situation. Furthermore, the members of the Isaac Brock Society have proven that they are very knowledgeable about this issue and are perfectly capable of evaluating the value (or not) of specific legal advice.

But, the main purpose of this post is as follows:

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