There is a new website that launched several weeks ago that I highly recommend: www.isaacbrocksociety.com. The engines behind this site are people I know and it has good, first-hand information about
- expatriation (as in giving up U.S. citizenship); and
- cleaning up paperwork problems for undisclosed bank accounts.
Offshore Bank Account Cases
I have done a LOT of work in the “clean up the undisclosed bank account” arena. I commend to you an article published today, titled “The OVDI Drudgery for Minnows.” What the author says is 100% true. This is from a tax practitioner (that would be me) who has handled many, many dozens of cases with the IRS and has advised an undisclosed but much, much larger number of people to find alternate ways to handle their affairs. I am very expensive. I suspect other tax lawyers experienced in this arena are also very expensive. Part of the expense is due to the difficult work, but his point about drudgery — endless hours grinding through the paperwork — is also spot-on.
FWIW I now only take on offshore disclosure cases with EXTREME reluctance. The absolute poop (this is an item of technical tax jargon and is somewhere in the Internal Revenue Code, I just can’t put my finger on it right now) the IRS put my clients through has utterly soured me on the experience. It chewed up Life Credit Units for me as the lawyer, as surely as it chewed up Life Credit Units for the clients.
My suggestion to those of you out there in the real world — first, get experienced, competent advice to decide whether you have a money problem or a jail problem with the IRS. It is well worth over-paying for that kind of advice.
After that, if you don’t have a jail problem I would be extremely reluctant to consign myself to oblivion as defined by the IRS’s now semi-permanent voluntary disclosure program. I am writing this blog post from the Al Faisaliah Hotel in Riyadh. U.S. persons living abroad almost cannot help but screw up one obscure IRS paperwork problem or another and thus risk massive penalties. But give the IRS 27.5%? NFW.
I must say that many OVDI cases that have opted out are being dealt with sanely. Some not.
I don’t want anymore of these cases. I know people. Call me and I will refer you to them.
In the meantime, read The Isaac Brock Society to get some education.
Expatriation
The reason I am in the Middle East is to talk to people about canceling their U.S. citizenship. Massive, massive interest in this.
Again, The Isaac Brock Society website is extremely useful. I especially like the first-hand reports of the exit interviews at different Consulates. This will really help you to know what to expect when you show up at an Embassy or Consulate to renounce citizenship.
Logging out of the citizenship/permanent resident status is the easier part. The tax part is more complex. For most of the authors who tell their stories on www.isaacbrocksociety.com I suspect they don’t have complex tax issues to solve when they expatriate. Our office more often than not lives squarely in “complexity” land. 
Anyway
I’m out of here. Headed up the road to see a friend who’s office is across from the Jarir Bookstore on Olaya Road here in Riyadh. I’m back in the office next week.
Carry on.
Hello to “Just Me” and Petros of The Isaac Brock Society.
Reader comments (6)
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Phil: Thanks for this recommendation. It means a lot. Do you mind if I reproduce it at Isaac Brock?
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Petros, you are welcome to reproduce it at TIBS.
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Phil,
Many, many thanks for the shout out and recommendation on the Drudgery piece. That means a lot to me, coming from you. You have been an inspiration and big help to a lot of us. You are one of a kind!
I toiled over the Drudgery post trying to decide whether I should also list your site as a reference for excellent information or not. In the end, for simplicity, I decided to focus on Jack’s blog. I knew you were moving on to other areas of practice, for real good reasons I could understand. I also figured, once folks start reading those threads at Jacks in the order I think they should, and if they follow my advice to then read references that are made there, they are going to come to the many many links I have made to specific posts that you did that were extremely helpful to me.
Your advice, and your wit, and general encouragement have kept me sane throughout this process, and I wish you nothing but continued success. Given the current course of IRS actions, you will be very very busy! Sad for America, but good for you!
All the best..
Cheers
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Phil
“I must say that many OVDI cases that have opted out are being dealt with sanely. Some not.”
Did you mean OVDI 2011, or OVDP 2009 here ? I’m asking because I didn’t know if 2011 cases are being processed yet.
Finally, I know you said you’ve given up on this, but could you expand on your statement a little bit about OVD opt-out cases ? I understand that you may still have clients in the process, and so can’t say much, or even if all your clients are through, can’t say much without violating confidence. Or you may with full justification say that anyone who wants that information should consult you directly (and pay for it) to get an individualized assessment of their own situation. But any information you can share would be appreciated.
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LVJ…
Since Phil is traveling, and may not be keeping up on comments, on Opt Out questions related to OVDI, maybe you would want to check out this link….http://federaltaxcrimes.blogspot.com/2011/12/opting-out-of-ovdi-and-ovdp-what-is.html
I would offer the opinion that each person’s facts are unique, so if you are at the stage of considering an Opt Out, paid advice about your own risks could be appropriate.
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Other than your post, is there a link out there for the pbiluc with the IRS announcement or from a secondary source, TNT or similar?