Potential high-risk SFCP participants enjoying the fruits (and vegetables) of their evil unpatriotic non-payment of U.S. taxes at a wet market in Shatin, a “new town” suburb of Hong Kong about an hour away from the central business district. Photo by Enoch Lau/Wikimedia Commons.
Yesterday, Roy Berg of Moodys wrote up a very helpful analysis (see also our discussion here) of the problems and uncertainties in the IRS’ new Streamlined Filing Compliance Procedures, also known here as Stealing From Canadian Pensioners. His comments are aimed primarily at Canadians, but are worth reading regardless of what country you live in. Below, I riff off several points of his in order to explore how the SFCP affects U.S. Persons in Hong Kong, and the likelihood that the IRS may classify you as a “high-risk” taxpayer for activities that everyone here would consider ordinary and innocent.