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| It is kind of you to post any links that may be helpful, so please take the following as well-intended: the article is simply negligent and wildly inaccurate in its description of the US tax code. There have been no substantive changes in the past few years, nor even in the "FBAR" (bank account) reporting requirements. (I've been filing that form for over seven years now - the requirement to file is not "new").
As an example, the author writes: "If you are a US citizen with a foreign company or partnership you have to file not just individual but corporate taxes and the penalty for failing to do so is $10,000 per year." Well, that is simply not true; you do not file "corporate taxes" in either case. Further, the penalty cited is not for non-filing of tax returns, but for non-filing of certain information returns.
Quite simply, any US citizen who has been filing an annual tax return and related information returns does not face any "new" issues or problems or taxes. Any citizen who has not been filing is an idiot, and doesn't deserve a lot of sympathy.
Last, but not least, the articles are a (perhaps predictable?) apology for UBS, with a charming omission of little details (UBS officers smuggling diamonds, advising on sham Hong Kong companies, conspiring to defraud the US Treasury, etc), and a brazen (and quite false) suggestion that UBS may not have realized it was breaking US law. | |
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The cited journalist is neither a jurist nor an accountant. Hence, the language is imprecise.
The substance is that taxpayers must disclose all global assets, including shares/investments in any company, partnership, etc. That is Swiss Law and apparently US Law, too.
The offense is non-disclosure of assets. The new development is the IRS determination to rigorously enforce US tax laws. And the IRS offers a last chance to confess...