Liberty and justice for all United States persons abroad

The Isaac Brock Society

Tag Archives: FBAR fundraiser

Is #FBAR relief for #Greencard holders with #offshore accounts on the way?

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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?).

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#Americansabroad in Switzerland should not enter #OVDP and join #FBAR Fundraiser

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From the RenounceUScitizenship blog.

This is a companion to the earlier post I wrote suggesting why Swiss banks should NOT join the OVDP program for Swiss banks. In this post I argue that individuals shouldn’t join OVDP for people. At the moment that means that nobody should join OVDP.

I have written a number of posts about the OVDP program for Swiss banks. The banks should stay away from it. But what does it mean for Americans in Switzerland? The answer is that they are being asked to prove that they are U.S. tax compliant. Remember that proof has nothing to do with proof.

U.S. tax lawyer Robert Wood (referring to Americans abroad in general) asks:

The Swiss banks are taking the lead in asking the question. One American in Switzerland  reports receiving the following message from Post Finance:

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Most Swiss banks considering #OVDP should NOT consider #Wegelin in their decision

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This post appeared on the RenounceUScitizenship blog.

2012 – Wegelin – Sowing The Seeds of U.S. Terror

This article includes:

Two months ago, Wegelin pleaded guilty, even though it had “little to gain” by doing so, it said in court documents. Wegelin said it was seeking “closure.” An attorney for Wegelin declined to comment.

Legal experts said the U.S.’s tactics may offer a blueprint for future actions against foreign banks. Assistant U.S. Attorney Daniel Levy wrote in a sentencing memo that the prosecution of Wegelin would send “a strong message to those who would believe that, without a physical presence in the U.S., they cannot be reached by U.S. law enforcement.”

“Americans who still have these undeclared accounts need to realize the world is shrinking,” Jeffrey Neiman, a former assistant U.S. attorney, said in an interview. He prosecuted UBS, UBSN.VX -0.31% the Swiss bank, for offenses similar to Wegelin’s.

But the legal theories the U.S. used in prosecuting Wegelin haven’t been tested under these specific circumstances. Had Wegelin gone to trial, legal experts said, it could have argued that it had no criminal intent because it didn’t believe it was responsible for adhering to U.S. laws. In Thursday’s court filing, Wegelin said it went to great lengths to attempt to comply with U.S. laws and that it didn’t know it would be punished for “what it was legally entitled to do under Swiss law.” It added: “Swiss banking privacy and its potential for concealing tax evasion by U.S. persons has never been a secret.”

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Required reading for countries considering a #FATCA IGA with the US – @PMHarper take note

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This post appeared on the RenounceUSCitizenship blog.

 

Basking in the glory of OVDP and the FBAR Fundraiser for Individuals:

The Department of Justice Announces OVDP for Banks!

On August 30, 2013 the U.S. Department of Justice created a voluntary disclosure program for Swiss banks. It was clearly premised on the OVDP program for people. My post describing OVDP for banks ended with:

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DOJ #FBAR lawsuit may test 8th amendment! It’s about time.

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Prologue – Department of Justice Exhibits Trophies from FBAR Fundraiser (http://www.justice.gov/tax/offshore_compliance_intiative.htm)

Disclaimer: I want to make it clear that I support the principle that one should obey the law. I do believe tax evasion should be punished. But, I also believe that punishments should be proportional to the crime. It is becoming increasingly clear that FBAR penalties violate any conceivable principle of fairness and morality. Good citizenship requires one to support the principle that it is important that the government adhere to high moral principles and standards. Given a choice of having offshore tax evasion and a completely unprincipled and predatory government, I would opt for the former.

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Note that they proudly include the Curran widow who they simply extorted 21 million dollars from. This makes me sick for the reasons given here. The U.S. government is not A predator. The U.S. government is THE predator. The time has come for these “so called” lawyers to put their energy into a search for justice rather than a search for fees (click on the previous link – really).

It appears that the names on the trophy list are people who have agreed to pay the fines. They probably thought that by “paying” they would put their adventures in FBAR behind them. They are wrong. They will need counseling the rest of their lives.

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Fareed Zakaria – Immigration lessons for the U.S. from around the world – Getting them in and keeping them in!

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Cross posted from RenouceUScitizenship

 

Last night I watched Fareed Zakria host a very interesting show:

Immigration lessons for the U.S. from around the world

Mr. Zakaria – Thank’s for a job well done! I assume the Podcast will be available soon. Continue reading →