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Old 07.12.2014, 10:06
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IRS DOES believe Americans are tax cheats - confirmed

Picked up from an Isaac Brock Society poster:

http://tax-expatriation.com/2014/12/...-from-the-irs/

Taken from their own training material.

"Most U.S. taxpayers using an offshore entity or structure of entities to hold foreign accounts are simply hiding the accounts from the Internal Revenue Service and other creditors . . ."

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Old 07.12.2014, 10:43
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Re: IRS DOES believe Americans are tax cheats - confirmed

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Picked up from an Isaac Brock Society poster:

http://tax-expatriation.com/2014/12/...-from-the-irs/

Taken from their own training material.

"Most U.S. taxpayers using an offshore entity or structure of entities to hold foreign accounts are simply hiding the accounts from the Internal Revenue Service and other creditors . . ."

And apart from your dramatic headline, they are probably right in this case often enough to make it a reasonable assumption. You will also find that most other revenue services around the world make similar assumptions.

If you think about it, it is not an unreasonable assumption: the ordinary Joe or Mary does not need those kind of structures to conduct their financial affairs and it takes time and a lot of cash to set something like that up. So people do not do it just for fun!
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Old 07.12.2014, 10:54
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Re: IRS DOES believe Americans are tax cheats - confirmed

Ordinary citizens need "foreign" bank accounts in the countries they live/work in outside the US. In no way does that suggest to anyone, except the IRS et al, that they're deliberately hiding money when doing so. I have no problem with the IRS saying some or even many, but most! Sorry, not in this day and age of globalisation.
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Old 07.12.2014, 11:21
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Re: IRS DOES believe Americans are tax cheats - confirmed

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Ordinary citizens need "foreign" bank accounts in the countries they live/work in outside the US. In no way does that suggest to anyone, except the IRS et al, that they're deliberately hiding money when doing so. I have no problem with the IRS saying some or even many, but most! Sorry, not in this day and age of globalisation.
What part of "using an offshore entity or structure of entities to hold foreign accounts" do you think would apply to "most" US citizens living and working abroad?
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Old 07.12.2014, 11:35
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Re: IRS DOES believe Americans are tax cheats - confirmed

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Picked up from an Isaac Brock Society poster:

http://tax-expatriation.com/2014/12/...-from-the-irs/

Taken from their own training material.

"Most U.S. taxpayers using an offshore entity or structure of entities to hold foreign accounts are simply hiding the accounts from the Internal Revenue Service and other creditors . . ."

I read it "most US taxpayers using an offshore entity or structure of entities to hold foreign accounts" and not "most US taxpayers period".
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Old 07.12.2014, 13:26
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Re: IRS DOES believe Americans are tax cheats - confirmed

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"Most U.S. taxpayers using an offshore entity or structure of entities to hold foreign accounts are simply hiding the accounts from the Internal Revenue Service and other creditors . . ."
I think this was written mostly about people who own and operate shell companies that transfer funds around from different accounts/companies (that don't really exist except on paper) in order to avoid taxes. Example: Mitt Romney's corporation headquarters in the Caribbean that is just a PO Box. It's not about little fries with a single bank account to function in the country where they live and work.

BUT - I think the interpretation by most, including IRS agents, is as you interpreted - anyone living abroad is clearly a crook wanting to hide money, because why would you not want to live in the greatest country on earth and keep all your money there!
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Old 07.12.2014, 14:50
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Re: IRS DOES believe Americans are tax cheats - confirmed

The US tax system keeps shifting the tax burden from legal entities over to (lower-income) natural persons. What OP complains about is merely a consequence of that multi-decennial trend, as is an ever-increasing share of corporate profits, along with a disproportionately increasing share (of both income and wealth) of the (ultra-)high-income earners.

Long story short:
Medea, though you have a point you're barking up the wrong tree. Cure the illness instead of the symptoms by working for a re-balancing of the american tax system.
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Old 07.12.2014, 15:16
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Re: IRS DOES believe Americans are tax cheats - confirmed

This is from a Letter to the Editor of The Economist in July 2014, written by Mark J. Mazur, Assistant Treasury Secretary. Since the IRS is part of the U.S. Treasury, I would expect that what he has written reflects IRS policy:

"It is also important to note that FATCA’s requirements are the same for all American taxpayers—expats are treated no differently. All citizens are required to comply with United States’ tax laws and FATCA is a tool to enforce them. Tax evaders should rightly worry that FATCA will reveal their illicit activities."

http://www.economist.com/news/letter...letters-editor

The "illicit activities" mentioned by the Assistant Treasury Secretary are the ordinary household and business finance engaged by Americans who live abroad. You know, receiving a monthly salary, paying rent, shopping at Migros. The Assistant Treasury Secretary is a fool.
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Old 07.12.2014, 17:43
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Re: IRS DOES believe Americans are tax cheats - confirmed

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The US tax system keeps shifting the tax burden from legal entities over to (lower-income) natural persons. What OP complains about is merely a consequence of that multi-decennial trend, as is an ever-increasing share of corporate profits, along with a disproportionately increasing share (of both income and wealth) of the (ultra-)high-income earners.

Long story short:
Medea, though you have a point you're barking up the wrong tree. Cure the illness instead of the symptoms by working for a re-balancing of the american tax system.
I agree Urs Max, that is where the ultimate solution lies. Unfortunately it's likely to take many years, if not decades, before that happens. Yes, the Republicans are more or less committed to repealing FATCA and overhauling the system, but I don't see either as being high on their "to do" list once they get re-elected. They themselves said giving their backing to these two subjects is all about garnering votes/donations for the 2016 elections. Once they've got our votes/money I don't see them really following through I'm afraid. At least, not in the short term. Which is why I'm glad I got out when I did.
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Old 07.12.2014, 19:03
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Re: IRS DOES believe Americans are tax cheats - confirmed

US citizens abroad have been under attack by US politicians for decades and there is no reason to expect that this will change. A Chicago Tribune journalist wrote in 1979 that Senator Proxmire "sneered at overseas Americans as “mink-swathed, high-living jet-setters living at the taxpayer’s expense.” "

The article goes on to correct this misconception but, of course, the situation has gotten even worse in recent years under Obama, Carl Levin and others:

"Most Americans abroad, in fact, are hard-working businessmen, teachers, or other wage slaves. They are bitter, and some are taking out their bitterness by trading in their passports.

Many American companies are bitter, too. Most companies pay tax-equalization that can add $5,000 or more to the annual upkeep of a middle-management employee. The trouble is that these allowances are taxable, too, producing an allowance-tax-allowance-tax cycle. for a top management man earning $150,000, the tax-equalization allowance could rise to $434,000, according to Business International, a research firm based in Geneva.

The result is that many are returning home – the number of Americans overseas is believed to have shrunk from 1.7 million to 1.5 million in recent years. Others, like Williamson, have stopped being Americans. And companies are replacing Americans in their overseas operations with other nationalities.

What this means, of course, is that export business that depends upon national ties is going to other nations.

“One of the indices of a great international power is the number of quality of its expatriate citizens in their international marketplace,” American lawyer William Havemore wrote from Rome. “To discourage multinational enterprises from staffing their offices with Americans is just plain stupid.”

http://news.google.com/newspapers?ni...g=5502,3644640
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Old 07.12.2014, 19:13
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Re: IRS DOES believe Americans are tax cheats - confirmed

I agree, absent pressure they're not too likely to follow thru. I mean, most congress members are in the very same tax bracket that profits most from the current scheme, and it would be foolish to expect them to act against their own interests out of mere kindness.

Just to take one example, Mitt Romney & wife are estimated at $250mln, plus another 100mln in a fund for their children. And they owe that wealth to a decent length to "tax optimization", which includes offshore entities and trust funds. His tax rate is around 14%, considerably less than what's to be paid on wage income.

In effect, the same things that are illegal for individuals, are completely legal for corporations. In a democracy every nation gets the government (and thus the tax system) they voted for, even if they did so merely indirectly.
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Old 07.12.2014, 19:58
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Re: IRS DOES believe Americans are tax cheats - confirmed

Unfortunately with the costs of running a campaign election the US is turning more and more into a government of the rich people, by the rich people for the rich people.

Interesting article on the Guardian.com website on the whole democracy thing.

http://www.theguardian.com/commentis...ican-democracy
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Old 07.12.2014, 20:34
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Re: IRS DOES believe Americans are tax cheats - confirmed

Two points on this:

"Most U.S. taxpayers using an offshore entity or structure of entities to hold foreign accounts are simply hiding the accounts from the Internal Revenue Service and other creditors . . ."

I actually do not see anything false with this statement. Maybe "most" is a bit excessive, but one can't deny that A LOT of U.S. corporate or high net-worth individual taxpayers have really come up with creative structures to minimize their U.S. tax liability, fully aided, if I must say, by extremely foreign-taxpayer friendly (i.e. borderline aggressive) tax regimes in other countries, one of which the one where you all live (CH) and another of which the one where a lot of you are from (UK patent box regime, anyone?).

And why wouldn't the above taxpayers take advantage of these tax friendly policies, may I add, if this is done using legally available means as allowed by the U.S. tax code or others? However, remember there are always two sides on every transaction that gives rise to a taxable event - both sides will want a bigger share of the pie, and taxpayers really need to pick and choose their fights. So in short, you can play in the Alps or in London or fly under the IRS radar, but most times, not both.

Note I explicitly talked about some categories of taxpayers, as above, not all U.S. taxpayers. Your average Jane Doe will likely NOT need/not have these complicated entity structures, and yet, is caught in the unpleasantness of having to deal with the repercussions of FATCA et alia.
It looks to me like the typical case of throwing away the baby wth the water - in order to go after the big, bad guys, the IRS creates difficulties to honest Jane Doe taxpayers - but frankly speaking, as unpleasant as it is, you can see where the government priorities lay, and they are not with the honest, tax paying, U.S. private citizens abroad. This is really the complaint that should be directed to the IRS, in my opinion.

Second point, the U.S. is not alone in this, and it's actually lagging behind in terms of pursuing taxpayers that are (or are perceived to be) shifting taxable income. If you can't sleep at night, take a look at all the fun stuff the OECD has been coming up with on the matter of Base Erosion and Profit Shifting. Most of us in the practice think that some OECD country will bite the bullet already in 2015 (I put my money on Germany, who is already going after the UK for their introduction of the patent box regime - the Deutsch did not like that one a single bit). I don't think anything is really gonna happen on this in the U.S. until the presidential elections - I don't see either candidates wanting to piss off their corporate sponsors with increased compliance burden before getting elected.

My two (lenghty) cents...
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Old 08.12.2014, 00:42
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Re: IRS DOES believe Americans are tax cheats - confirmed

A well-written New York Times opinion piece by a British-American who will renounce his US citizenship in January.

"Why I'm Giving Up My Passport"

http://www.nytimes.com/2014/12/08/op...-passport.html
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Old 08.12.2014, 09:05
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Re: IRS DOES believe Americans are tax cheats - confirmed

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A well-written New York Times opinion piece by a British-American who will renounce his US citizenship in January.

"Why I'm Giving Up My Passport"

http://www.nytimes.com/2014/12/08/op...-passport.html

Excellent article. Typical idiot comments. Why are people so offended by these decisions?
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Old 08.12.2014, 12:38
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Re: IRS DOES believe Americans are tax cheats - confirmed

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Unfortunately with the costs of running a campaign election the US is turning more and more into a government of the rich people, by the rich people for the rich people.

Interesting article on the Guardian.com website on the whole democracy thing.

http://www.theguardian.com/commentis...ican-democracy
Very true. The presidential election to me is coming ever closer to the Roman elections - the biggest pocket providing the best perks is the one who will win. PACs and SuperPACs come to mind - how a non-natural person can be assigned any political rights and/or be allowed to produce political content is beyond me.
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Old 08.12.2014, 13:23
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Re: IRS DOES believe Americans are tax cheats - confirmed

Dr. Amanda Klekowski von Koppenfels, a Migration Studies professor at Kent University, Brussels campus, is conducting a survey on Americans abroad and their views regarding US citizenship renunciation. The survey is relatively painless:

https://www.surveymonkey.com/s/the_US_and_you
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Old 08.12.2014, 15:43
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Re: IRS DOES believe Americans are tax cheats - confirmed

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Excellent article. Typical idiot comments. Why are people so offended by these decisions?
As mentioned in my post above, the average American just cannot believe anyone would want to live anywhere but the U.S.

I get it all the time when I go home. How could Switzerland possibly be better than the good 'ol USA? Why on earth did I marry a Swiss man and move halfway around the world when there are plenty of (American-style) football-loving, beer-drinking, rednecks where I come from? It simply does not compute.

Much like the Bernese Swiss, I must admit. Most of the ones I know haven't moved out of the canton in their entire lives. Some not even out of the same village.
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Old 08.12.2014, 16:22
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Re: IRS DOES believe Americans are tax cheats - confirmed

Yeah, I know. My question was rhetorical. I think it's everywhere.
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Old 09.12.2014, 01:00
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Re: IRS DOES believe Americans are tax cheats - confirmed

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As mentioned in my post above, the average American just cannot believe anyone would want to live anywhere but the U.S.

I get it all the time when I go home. How could Switzerland possibly be better than the good 'ol USA? Why on earth did I marry a Swiss man and move halfway around the world when there are plenty of (American-style) football-loving, beer-drinking, rednecks where I come from? It simply does not compute.

Much like the Bernese Swiss, I must admit. Most of the ones I know haven't moved out of the canton in their entire lives. Some not even out of the same village.
Hahaha! Your post made me

I get that a lot from Italian friends: why on earth would you want to live in the USA where they dress horribly and drink crap wine and so on and so forth. Note: this coming from small town folks who, aside from all-inclusive beach resorts, have never set foot outside the country. Conclusion: rednecks are everywhere - better or worse dressed, beer or wine-drinking
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