This is cross posted from the RenounceUScitizenship blog.
This post should be read with a previous post: “The taxpayer, the IRS and the “professionals” – where to go from here“. This post will suggest why, given the IRS shift in policy on March 1, 2011 lawyers had difficulty advising clients whether to enter OVDI (2011). With the exception of the most extreme cases (clear tax evasion at one end vs. Ambassador Jacobson’s 70 year old Gramma at the other), lawyers neither trusted nor understood the IRS. They could not. This post will suggest why. At the outset, it is important to recognize that “hindsight is always twenty twenty” and during the desperate summer of 2011, nobody had the benefit of hindsight.
The facts and issues are summarized by the conclusion of Taxpayer Advocates directive to the IRS on August 16, 2011: Continue reading
