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Feedback from U.S. expatriate on FBAR compliance offshore

From a real live U.S. citizen living abroad:

“Eighty percent of the people here don’t know about the requirement.  Of the twenty percent, most of them say ‘The IRS can go to hell.'”

For Commissioner Shulman:

1. Is this merely anecdotal or is it a statistically-representative data point?
2. If this is an accurate reflection of taxpayer knowledge, attitudes, and voluntary compliance, let’s ask the rhetorical question.  “Why?”

Opinion: the percentages may be misplaced. The ignorance of the law is real. The deliberate disregard of the law is real, and the reason most-often cited is that the penalties are mind-bogglingly disproportionate.