Mr. Bedrosian (a pioneer in FBAR history) meets Mr. #FBAR: The good, the bad and the ugly

Why the Arthur Bedrosian meeting with Mr. FBAR is important Synopsis: The Bedrosian FBAR case is an incredibly important victory for taxpayers. Judge Baylson first ruled that FBAR “willfulness” in the “civil” context did NOT require knowledge that filing an FBAR was a legal duty (the criminal standard). He then ruled that Mr. Bedrosian’s failure […]

U.S. “culture of penalty” and inflation: First, inflation used to increase the size of #FBAR penalty base and then to increase the size of actual penalties

Introduction: Penalty as a part of American Culture "U.S. tax, form and penalty club": Google "IRS penalty as part of American culture" and see a wide range of results — Citizenship Lawyer (@ExpatriationLaw) June 25, 2017 The above tweet links to a wide range of examples of America’s culture of penalty. The purpose of […]

Mr. Pomerantz meets Mr. #FBAR in the Homeland: The “willful” FBAR penalty requires proof of “willfulness”

Looking for Mr. FBAR This is one more in a series of posts discussing the FBAR rules. The FBAR rules were born in 1970, laid virtually dormant until the 2000s and then were then unleashed in their full “ferocity” on U.S. persons. A good review of the history of Mr. FBAR is here. A discussion […]

Did Mr. #FBAR really pay a surprise visit to Canada?

Update June 19, 2017: The Department of Justice sued Mr. Pomerantz in Seattle. The purpose of the lawsuit was to get a judgment against Mr. Pomerantz. Interestingly, the Government lost the lawsuit for reasons unrelated to the substance of the issue. The Government failed to plead the facts that it needed to succeed in the […]

Part 2: Be careful what you “Fix For” – Mr. Kentera meets Mr. #FBAR in the “Twilight Zone”

Introduction … Most meetings with Mr. #FBAR take place in "The Twilight Zone" — Citizenship Lawyer (@ExpatriationLaw) February 5, 2017 This post is one more of a collection of FBAR posts on this blog. The most recent FBAR posts are here and here. The “unfiled FBAR” continues to be a problem for certain […]

Be careful what you “fix for”! A Holiday Gift: What to do about the unfiled #FBAR

As 2016 comes to an end … Received #greatholidaynews today from two "ecstatic" renunciants who confirm that the wait time for CLNs is down to 2 – 3 months in Canada! — Citizenship Lawyer (@ExpatriationLaw) December 17, 2016 I suspect that history will show that that the growth in renunciations of U.S. citizenship (and abandonment […]

Citizenship-based reporting: Mr. #FBAR as a role model for President Putin and the Russian government

Via @NPR: Steven Seagal Is Now A Citizen Of Russia, Courtesy Of Putin – Welcome to the Russian version of Mr. #FBAR — Citizenship Lawyer (@ExpatriationLaw) November 22, 2016   It has been widely reported that American actor Steven Seagal has joined American boxer Roy Jones in becoming a citizen of Russia. By becoming […]

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 […]

Around the world in 192 pages: Experiences of #Americansabroad in an #FBAR and #FATCA world

@ExpatriationLaw is this still available or posted anywhere? — CrossBrit (@CrossBriton) October 29, 2016 Here it is: richardsonkishcommentsamericansabroadapril152015internationaltax-2 This is one of seven parts of the Richardson Kish submissions to the Senate Finance Committee in April of 2015. I thank Patricia Moon for her unbelievable effort in putting this document together! And speaking of Americans […]