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October 3, 2011 - Phil Hodgen

New Brunswick Premier is in the OVDI

The Premier of New Brunswick is in the OVDI.  In an article published on Saturday in the online Telegraph-Journal, we see a prominent Canadian politician’s reaction to getting squeezed by the IRS.

[Premier David] Alward was born in Beverly, Mass., and spent his early years in the United States before his family settled in New Brunswick.

“I’ve had to scramble like thousands of other people,” Alward said, adding that he is complying with the U.S. demand for tax returns going back years and detailed disclosures.

“This is a difficult situation for a lot of people. I can tell them I am going through the very same thing they are going through.”

There is a hint in the article that in Ottawa pitchforks and torches are being mustered.... continue reading

Voluntary Disclosure
September 30, 2011 - Phil Hodgen

For people at risk who did not enter the OVDI

For God’s sake go get experienced, competent legal advice.  Now.  Before you take action.  Don’t go to a tax mill (I learned yesterday from a phone call that one of these tax mills that does “Settle with the IRS for pennies on the dollar!” is offering to do this kind of job at a fixed cost of $20,000.  Holy F-ing S—.)

I’m getting a series of phone calls from people who–due to terror–jumped into the tender, loving arms of the IRS after the September 9, 2011 deadline closed for the OVDI.  Actually, I get calls from people who were buffaloed into the OVDI by reason of fear of criminal tax prosecution, who say “what are my options now?”

Yes, there is an urgency and a need to make a decision about what to do.... continue reading

Americans Living Abroad Voluntary Disclosure
September 26, 2011 - Phil Hodgen

Has the IRS crossed the RRSP Rubicon?

Regular readers of this blog know that I talk frequently about RRSPs.  (For those of you who don’t know, RRSPs are Canadian “do-it-yourself” pension plan arrangements, like an Individual Retirement Account (“IRA”) in the United States.)  A whole bunch of OVDI participants are about to go down the rabbit hole to Alice-in-Wonderland tax logic, as the Commissioner tries to decide what to do with RRSPs.

Here is the problem in a nutshell.

  1. RRSPs are “foreign financial accounts” for purposes of the FBAR filing requirement (Form TD F 90-22.1).  No question about it.
  2. RRSPs are pension arrangements.  It is IMPOSSIBLE to do any skanky tax evasion games with an RRSP–in Canada or the United States.
... continue reading
RRSPs Voluntary Disclosure
September 23, 2011 - Phil Hodgen

Questions I answered for a reporter about RRSPs and OVDI

I got an email from a reporter, asking some questions about the OVDI and RRSPs.  Here is my email back to her.  I will be talking to her on the phone as well.

Phil,

I am working on another OVDI article. This story is about foreign retirement plans, RRSPs in particular. I know that you have written about this topic on your blog, and I am hoping that you might have some insight into how these plans are likely to be treated within the context of the OVDI. Have you had any discussions with agents or the OVDI hotline regarding the treatment of RRSPs?

... continue reading
RRSPs Voluntary Disclosure
September 20, 2011 - Phil Hodgen

is this the OVDI tipping point?

http://m.theglobeandmail.com/news/opinions/opinion/help-im-on-the-irs-hit-list/article2171697/?

This article has more than 300 comments. Finally Mr. Shulman has hit the mainstream consciousness, but not in the way he anticipated.

Canada holds the moral high ground here. This may mark the tipping point at which diplomacy and sanity force Mr. Shulman’s retreat. I hope so.

Go Canadians.

Oh by the way. You Canadians in the OVDI. Prepare to give Mr. Shulman 25% of your RRSPs. How does that make you feel?

Thanks correspondent D.... continue reading

Voluntary Disclosure