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April 14, 2015 - Phil Hodgen

RRSPs never reported on FBARs

I swore a mighty oath on a skyscraper of Bibles to never write about RRSPs again, so pretend that this is a post about FBARs and not RRSPs at all.  That is actually semi-accurate because the logic applied here need not only apply to RRSPs.

A gentleman posted a comment on The Last RRSP Post Ever and I thought it would be worth promoting it to blog post territory in order to give it greater visibility:

So what is the semi-nearly-somewhat nearly way  to fix it I have not filed FinCen Form 114 for the past 5 years? I have been in US since 2000 and have been filing 8891 every year since 2004… and didn’t realize I need to include RRSP in FinCen until I found out that 8891 become obsolete :(.

... continue reading
RRSPs Voluntary Disclosure
October 1, 2013 - Phil Hodgen

Sooner or later, secrecy fails as a tax planning strategy


The train is headed straight at you. You cannot tell how far away it is. You can step off the tracks to safety.

Alt: you’re naked but you don’t know it yet.

British Crown Dependencies and Overseas Territories

I know that there are a lot of you out there with corporations, trusts, foundations, and other holding structures. You are relying on the “How not to be seen” strategy. (YouTube. You might laugh out loud. You Have Been Warned.)

I know this because I have set these structures up, and I have torn them apart. I have defended clients with Very Serious Problems involving these structures.... continue reading

US Real Estate Investments Voluntary Disclosure
July 10, 2013 - Phil Hodgen

Opt out (of the OVDI) and get out (of the USA)

We get questions. This one came as a comment to a prior blog post. Lightly edited, it says:

I am a dual citizen in middle of OVDI and was planning to return to my home country for personal reasons. Have paid back taxes but haven’t gotten to point of deciding whether to opt out. Should I wait until its resolved? Can I negotiate better from a foreign country?

Here’s the answer.

I have no idea about your situation and your OVDI. I don’t know whether you are one of the many ordinary people who entered the OVDI with good intentions only to have see the true glory of the train wreck that is the OVDI process.... continue reading

Expatriation Voluntary Disclosure
May 10, 2013 - Phil Hodgen

Decline of American Civilization, Form 8938 Edition

We’re working on a tax return project. It involves a 2012 Form 8938 (PDF).

Forty-six (multi-word obscenity deleted) pages long.

That’s how long the Form 8938 is, in draft form.

And we ain’t done yet, pardner. This here thing might be getting’ biggerer a’fore we’re done.

And of course there’s the FBAR that goes along with this project.

This is how American civilization dies–one spectacularly ill-conceived idea at a time, (ahem) emitted by Congress and the Treasury Department.

Let’s just bury the world in useless paperwork, shall we?

Sheesh.... continue reading

Voluntary Disclosure
April 28, 2013 - Phil Hodgen

Note to Concerned Immigrant

A reader who nicknamed himself/herself “Concerned Immigrant” left me a message from the Contact page of this site.

Hi Concerned Immigrant. I sent you am email in response. It bounced because you gave an obviously fake email address.

Perhaps you just wanted to vent your anger at the FBAR stuff your parents face.

Anyway. Here is the gist of the response I tried to send you.

(1) Do everything correctly for 2012. Don’t miss this deadline.

(2) Get some competent advice about how to handle the past years. If the advice is OVDI, then stand up and walk away, swearing the mightiest oaths that a drunken sailor could swear.... continue reading

Expatriation Voluntary Disclosure