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Tag Archive for covered expatriate

False Form 8854 Used As Part Of “Willful” FBAR Prosecution

The primary story is of a U.S. professor who pleaded guilty to an FBAR violation and was subjected to a 100 million FBAR penalty. Notably the “tax loss” was 10 million dollars and the FBAR penalty was 100 million dollars. It appears that Mr. FBAR is becoming an important tool in the arsenal used by the United States Treasury.

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The Internal Revenue Code Versus The IRS Form: Noncovered Expatriate Status And Form 8854

John Richardson

 For Whom The IRS Form Tolls

I would not want the job that the IRS has to create forms given there are many “information reporting requirements” in the Internal Revenue Code. The IRS has the job (sometimes mandatory “shall” and sometimes permissive “may”) of having to create forms that reflect the intent of the Internal Revenue Code. The forms will not necessarily reflect how the IRS interprets the text and intent of the Code. Once created, the “forms” become a practical substitute for the Code. If you look through your tax return you will find “form” after “form” after “form” how the various provisions of the Internal Revenue Code are “given meaning” (if the meaning can be determined).

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Part 3 – Understanding “Exit Taxes”

“The “Exit Tax” affects “covered expatriates” – what is a “covered expatriate”?”

In a FATCAesque world, where “relinquishments” are becoming a form of “self defense”, it’s important that you understand:

Issue A – Who is affected by the Exit Tax? What is a “covered expatriate”? Only “covered expatriates” are subject to the “Exit Tax”

1. What are the sections of the Internal Revenue Code that govern the Exit Tax?

2. Who is subject to the “Exit Tax” and why? Read more