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  1. I couldn’t agree more – a total repeal of FATCA is what’s needed along with this silly citizenship-based taxation. In the UK I’ve kicked off the process writing to my MP and others to find out if the HMRC will do the same as Canada and announce it will not collect FATCA/FBAR penalties.

  2. This is where the logic that Phil talks about comes in to play You need to use it to interpret the “relief” nonsense the IRS is spewing out.

    IF we just repeat already existing law and pretend it something new, THEN these troublesome Canadians will shut up.

    IF we give minimal relief to a small group of Canadians, THEN we can look constructive without really changing anything.

    IF we ignore the rest of the world, THEN we can still collect these horredous FBAR penalties.

    We need to see the guidance, but the relief for Canadians appears to be iff (that’s if and only if) a Canadian did not owe taxes. While the Canadians lucky enough to be in this position will rejoice if they mistakenly entered OVDI, there are still many, many Canadians who owe minimal tax due to differing accounting rules between the countries

    So, IF 1,2 and 3 above, THEN decency from the IRS re FBAR penalties is roughly equivalent to 0.

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