# More Questions about Fbar and Filing



## celticweb

Hi Everyone
I posted last week for the first time after finding out about US citizenship tax. 

I am in the process of gathering all my information however I have a few more questions if someone can be so kind to help. Forgive me if this has been answered elsewhere on the forum.

1. How do we file tax returns, is it e-file or by post? If you use software, can you e-file with the software?

2. For the Fbar it says use the exchange rates from the treasury website which is fine, i found the website and said to use the last day of the year december 31st. however the exchange rate for pound sterling makes no sense. For example, if the exchange rate for 2014 is FC to $1.00 at 0.6050 how do you work that out. for example £10,000 what is that using exchange rate 0.6050 to dollars? I didn't think i was this bad at math.

3. does a private defined contribution pension go on Fbar if the pension hasn't been cashed out yet?

It's all so confusing for me as a first timer. 

Thank you in advance.


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## Pro.wolf

celticweb said:


> Hi Everyone
> I posted last week for the first time after finding out about US citizenship tax.
> 
> I am in the process of gathering all my information however I have a few more questions if someone can be so kind to help. Forgive me if this has been answered elsewhere on the forum.
> 
> 1. How do we file tax returns, is it e-file or by post? If you use software, can you e-file with the software?
> 
> 2. For the Fbar it says use the exchange rates from the treasury website which is fine, i found the website and said to use the last day of the year december 31st. however the exchange rate for pound sterling makes no sense. For example, if the exchange rate for 2014 is FC to $1.00 at 0.6050 how do you work that out. for example £10,000 what is that using exchange rate 0.6050 to dollars? I didn't think i was this bad at math.
> 
> 3. does a private defined contribution pension go on Fbar if the pension hasn't been cashed out yet?
> 
> It's all so confusing for me as a first timer.
> 
> Thank you in advance.




1) I mailed the forms to the streamlined offshore program office in Austin, Tx (I filed under this program)
2) I used the average year rate (well, the cpa I used). Table is https://www.irs.gov/Individuals/International-Taxpayers/Yearly-Average-Currency-Exchange-Rates 
Conversion to US dollar based on example: 10000/0.6050
3) I listed all my retirement and pension accounts even though I will not get any income from them until I retire


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## celticweb

Hello
thank you but re the exchange rate, how do you actually calculate it.

if i take £10,000 x 0.656 it becomes $6050 so that can't be right or if i divide it, it becomes $15243 which also doesn't seem right. what am i doing wrong
how do you calculate this? how do you actually convert using that 0.656

thank you.


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## celticweb

actually maybe dividing it is right?


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## Pro.wolf

celticweb said:


> Hello
> thank you but re the exchange rate, how do you actually calculate it.
> 
> if i take £10,000 x 0.656 it becomes $6050 so that can't be right or if i divide it, it becomes $15243 which also doesn't seem right. what am i doing wrong
> how do you calculate this? how do you actually convert using that 0.656
> 
> thank you.


Pounds is a stronger currency that US dollars. You divide pounds amount by the rate in table, pretty sure


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## celticweb

Yes that seems right, divide it for the pound.

also re the pension that you said you reported on Fbar.
How did you get the value of the pension to put on the Fbar? Did you use the value from an annual statement? I have to file using streamlined and don't know the value for past 6 years. maybe could find out though. or write value unknown?

Thank you so much.


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## Pro.wolf

celticweb said:


> Yes that seems right, divide it for the pound.
> 
> also re the pension that you said you reported on Fbar.
> How did you get the value of the pension to put on the Fbar? Did you use the value from an annual statement? I have to file using streamlined and don't know the value for past 6 years. maybe could find out though. or write value unknown?
> 
> Thank you so much.


I was able to get my annual balances online. My pension is thru my employer


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## celticweb

Thank you.
that's not the case for me. mine is private not through employment and not online. i will have to ring them up to see if they can send statements for those years.

thank you again.


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## Bevdeforges

Pretty much agree with most of the information you've gotten so far, but a few clarifications.

1. As far as I know, you have to mail in the back filed statements. You can only e-file the current year's returns, but depending on your filing status, this can be tricky to impossible for an overseas taxpayer. Fill out your 2015 return using one of the available softwares (preferably one of the "free file" ones if you qualify) and see if you can e-file. But the prior years' returns you're going to have to mail on paper.

2. You're right - the way they give you the rates in that table, you take your amount in GBP (10,000) and divide it by the rate (0.605) to give you the equivalent amount in dollars.

3. Do you get any sort of statement (even just annually) on your pension fund? If so, the amount to report should be on that. Or, you could always take your most recent statement and estimate the prior year balances for doing the back filings. (They really don't check the "accuracy" of the balance you report. It's more to get an idea of the magnitude of the account.) If in doubt, add a few thousand to what balance to have or estimate. (There's no penalty for over-reporting and the number you give isn't used to generate any tax figure on your returns.)
Cheers,
Bev


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## celticweb

Hi Bev
so if you mail, do you have to send it with something secure like DHL or Fedex? How do you even know the IRS received it and it's OK?

The pension thing does have an annual statement, i actually found the statements for last 4 years so can ask for the other years I suspect. or calculate based on that. but i can't cash this in until retirement age.


thanks Marie


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## Bevdeforges

Frankly, I've never bothered with DHL or Fedex, though some people insist on sending even their annual tax returns that way. If you want some "proof" send it registered (don't bother with the "proof of delivery" bit). 

On the retirement plan, I'm tempted to say that if you can't access it in any way until retirement age, you may just want to forget about reporting it. But that could be a stretch, depending on the specific rules and regulations. The US "defined contribution" plans all tend to have loopholes where you can get at the money before retirement for specific events - buying a house, taking a loan from the plan, medical bills, etc. You have to be the judge here.
Cheers,
Bev


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## celticweb

Hi Bev
some tax advisors i spoke said don't bother reporting that, just report it when it becomes income. they also said irs don't even know themselves how it's to be reported.

others said just put it on fbar for informational purposes.

I definitely can't get at this plan until the earliest at age 55. it is meant to run until I am 60 years old. During the years i have to file, i was not an age to access it. i also don't control how the funds are spent. 

I guess i have to ponder this one. This is just such a maze for me but I am slowly getting there.

thanks for your help again. I am sure I will be back with more questions.


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## ForeignBody

The whole thing about pensions and the FBAR is confusing! You are not the only one to hit this. If you are getting annual statements it sounds like the pension is held in your name and you clearly have an interest in the account, so it seems to me that it falls within the FBAR definitions. Personally I would declare it. There is absolutely no harm in reporting it.


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## celticweb

For sure it is in my name, for sure it will be my pension when i am able to access it and for sure I can't get access now.

It's not with a financial institute like a bank though. If I can get access to real information from the past then probably best to be safe. I just worry about entering wrong information for value. I really wish there was clear guidance on this. 

thanks.


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## Bevdeforges

celticweb said:


> For sure it is in my name, for sure it will be my pension when i am able to access it and for sure I can't get access now.
> 
> It's not with a financial institute like a bank though. If I can get access to real information from the past then probably best to be safe. I just worry about entering wrong information for value. I really wish there was clear guidance on this.
> 
> thanks.


To be honest, the tax laws in every country are written for the financial instruments that exist in that country. The US has gotten itself into a huge muddle by trying to apply US tax law to the wide range of diverse financial instruments and set-ups there are across the world. Was just wondering myself how the US would expect someone here in France to report a usufruit interest in financial accounts or property - a distant possibility for me one day, perhaps. But I prefer to do a Scarlett O'Hara ("I'll think about that tomorrow...")

The safest approach is usually to disclose anything you're unsure of - in the simplest way possible. If anyone at the IRS bothers to look at it, they can see that you are hiding nothing, and if they need or want additional information, they'll ask. (For those of us in the lower income brackets, it's highly unlikely they'll ask - but even if they do, you're not hiding anything.)
Cheers,
Bev


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## celticweb

Probably better to report it for prudence but is the Fbar the only place it needs to be reported? There is no income or distributions for it. 

I do have to say that had I known about this fbar thing and tax situation in general, i don't think I would have started it. I started it with the intention of providing retirement for myself, what people are encourage to do and what people do in their every day lives. and certainly this plan isn't a vehicle for tax invasion in any shape or form. It makes me angry that I have no clear guidance on this and risk facing penalties for making a mistake. 

Than the value part, is it better to say value unknown or try to calculate a figure based on information I do have knowing this isn't going to be accurate. i am sure this plan goes up and down throughout the year.

Thanks


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## BBCWatcher

FinCEN Form 114's instructions define pretty much anything for reporting purposes as a "financial account," including a man or woman with a cigar box in a mountain village in Bangladesh who holds your (and other villagers') funds. So yeah, reportable.


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## Lulu78

BBCWatcher said:


> FinCEN Form 114's instructions define pretty much anything for reporting purposes as a "financial account," including a man or woman with a cigar box in a mountain village in Bangladesh who holds your (and other villagers') funds. So yeah, reportable.


Can someone correct me if I am wrong, but my understanding is that safety deposit boxes don't have to be reported on the FinCEN114's (that means neither will the cigar box holding the cash?!). I don't particularly care about the cigar box  I just want to make sure that my understanding is correct regarding safety deposit boxes?!


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## BBCWatcher

The ordinary contents of a safe(ty) deposit box -- jewelry, gold coins, wills and deeds, collectibles, Jason Bourne's passports, etc. -- is not IRS Form 8938 reportable per the IRS. That seems to be the same view Treasury holds.

Cash and cash equivalents (e.g. bearer bonds) held in a safe deposit box are probably reportable, however. (At least on FinCEN Form 114 -- that's what the instructions seem to say.) Also, if you have something other than physical gold (or precious metals) directly held -- such as gold certificates, or some sort of other proxy for precious metals -- then they might be reportable.

When in doubt, report. There's no penalty for over-reporting.


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## celticweb

Hi
What about Bitcoin? Are we meant to report that? thank you


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## Lulu78

Forbes Welcome

Unless things have changed since, I don't think so


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## Lulu78

I tried to post a link from an article in Forbs but it didn't let me! Google it, you should be able to locate the article!


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## celticweb

Hi Lulu

Thank you. I found the article. 

Btw I am in the same situation as you and just found out about the citizenship tax. So trying to get my affairs in order for peace of mind. I have been so stressed since finding out and have even lost weight. 

I am going to do the streamlined program too and then 2015 and 2016 and make a decision about renouncing. I don't mind if it's just filing some returns, it's just all the other things that come into it and you need a masters degree in international tax to understand and grasp all the requirements.

I will keep posting about my journey.


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## Bevdeforges

celticweb said:


> I am going to do the streamlined program too and then 2015 and 2016 and make a decision about renouncing. I don't mind if it's just filing some returns, it's just all the other things that come into it and you need a masters degree in international tax to understand and grasp all the requirements.
> 
> I will keep posting about my journey.


It really comes down to a personal decision based on your particular financial situation and your contacts (or lack thereof) back to the US. In my case, for instance, I have a fairly simple financial situation, with ties back to the US for such things as a bank account and social security (i.e. retirement) benefits in the balance.

It's a little bit of a nuisance to file each year, but as I get into retirement, it will allow me to pay what I owe on the retirement benefits. Luckily, the tax system of the country in which I live makes it fairly easy to indicate what income I have paid US taxes on and claim the proper credit and/or exemption (even if most income has to be reported on both returns). With certain types of investments here where I live, things would get complicated on the US side very very quickly - but so far I haven't had to worry about those sorts of things.
Cheers,
Bev


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## Lulu78

Hi Celticweb;
Take comfort in the fact that you aren't alone (& am sure you won't be the last either). Don't let it affect your health! Honestly it's not worth it! 
I am sure the IRS will be too busy sifting through the million "Panama Papers" to care about our non-wilful FBAR penalties 
It is a good idea to get the monkey off your back & then see how you feel about the citizenship. Hopefully this will put you in a better place to make a sound non-emotional decision. 
Good luck, & please keep us posted about your journey


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## iota2014

Lulu78 said:


> ...the IRS will be too busy sifting through the million "Panama Papers" to care about our non-wilful FBAR penalties


Absolutely. Questions will be asked of any US Persons named in the leak. Such as: "Why have you registered your shell company in Panama instead of Delaware?"


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## celticweb

The main thing bone of contention for me is that I am actually entitled to absolutely no benefits at all in the USA. I have been in the UK all my adult life (since age 13), never paid US tax, never worked in the USA, never paid into their system, social security etc. I don't use their highways or hospitals, i won't even get unemployment benefits. I am dual citizen because of the fact that I was born in the USA.

Having said that i don't want to make a quick decision. Generally it's always good to have citizenship in more than one country. That's why I am giving it until the 2016 return to decide. The rules might even change and be more friendly to expats. I think the rules should distinguish between American citizens working abroad temporarily and those that are based overseas permanently with a second citizenship. Those that are genuinely Accidental Americans should be exempt from a lot of this reporting. I know that's unlikely to happen but it would be a fairer system.

I am grateful I can come here for advise and talk to others who are in my situation or have been through it. And I always feel better after getting replies here.

I will definitely post again.


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## Bevdeforges

iota2014 said:


> Absolutely. Questions will be asked of any US Persons named in the leak. Such as: "Why have you registered your shell company in Panama instead of Delaware?"


Everything I've read so far says that there are very few Americans named in the documents. (Though at a couple of TB of data, they may still be sorting through it...) Still, I think the Americans actively hiding their ill-gotten gains, there are tax havens other than Panama.
Cheers,
Bev


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## iota2014

Bevdeforges said:


> Everything I've read so far says that there are very few Americans named in the documents. (Though at a couple of TB of data, they may still be sorting through it...) Still, I think the Americans actively hiding their ill-gotten gains, there are tax havens other than Panama.


Indeed. 

Speculations about the reason for the paucity of Americans:

Why Are Americans Not Included in the Panama Papers? - NBC News

Tax Research UK » Why are there so few US details in the Panama Papers?


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## iota2014

Interesting article about this question of the missing Americans at No US Names in Panama Papers Leak- Why Not?

Turns out there's a treaty. Of course there is.



> The Tax Information Exchange Agreement includes a clause, Article 5, that specifies the terms of information sharing between the two countries on tax related matters:
> 
> 
> 
> The competent authority of the requested Party shall provide upon request by the competent authority of the requesting Party information for the purposes referred to in Article 1 of this Agreement. Such information shall be exchanged without regard to whether the requested Party needs such information for its own tax purposes or the conduct being investigated would constitute a crime under the laws of the requested Party if it had occurred in the territory of the requested Party.
> 
> 
> 
> The Article goes on to make clear that Mossack Fonseca’s type of services would particularly be included in the information request:
> 
> 
> 
> Each Party shall ensure that it has the authority, for the purposes referred to in Article 1 of this Agreement and subject to Article 2 of this Agreement, to obtain and provide, through its competent authority and upon request:
> (a) information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity; and
> (b) information regarding the ownership of companies, partnerships, trusts, foundations, and other persons, including…. ownership information on all such persons in an ownership chain; in the case of trusts, information on settlors, trustees and beneficiaries; and in the case of foundations, information on founders, members of the foundation council and beneficiaries.
> 
> Click to expand...
> 
> If Panama had ever been an attractive destination for American offshore storage of funds, this agreement shut the door on that possibility.
Click to expand...


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## BBCWatcher

celticweb said:


> The main thing bone of contention for me is that I am actually entitled to absolutely no benefits at all in the USA. I have been in the UK all my adult life (since age 13), never paid US tax, never worked in the USA, never paid into their system, social security etc. I don't use their highways or hospitals, i won't even get unemployment benefits. I am dual citizen because of the fact that I was born in the USA.


Wait a minute. The United States federal, state, and local governments provided you a great many benefits (publicly provided goods and services) for "only" the first 13 years of your life. You know, "only" the second most governmentally expensive part of a typical lifetime, after old age. That's not nothing! The U.K. didn't incur those considerable expenses.

That said, tax systems are not fee for service systems. If they were, then 11 year olds would be paying taxes, too. But of course it doesn't work that way because most 11 year olds cannot pay taxes.

The U.S. government and its democratically elected representatives have decided that if you want to hang onto a U.S. passport then you might owe a bit of U.S. tax if you both (a) have some rather significant financial success (or better); (b) are not contributing tax revenues to your country of residence at a level equal to or greater than what you would in the U.S. This is a very straightforward deal, and it in part reflects the reality that children are different from adults. Don't like that deal? Then pay $2350 and renounce U.S. citizenship -- still a great deal less than U.S. taxpayers spent on you for your first 13 years. That seems like a _very_ fair deal to me, or at least I don't think too many people in the United States would find your situation "unfair."

....Back to the subject of this thread, and commenting on Bitcoin. When in doubt, over-report. Although there hasn't been any Bitcoin precedent yet, there was actually a court case involving somebody with accounts at PartyPoker and PokerStars, two online gambling sites for poker players. The court determined that those offshore accounts had to be reported on FinCEN Form 114.


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## Nononymous

celticweb said:


> The main thing bone of contention for me is that I am actually entitled to absolutely no benefits at all in the USA. I have been in the UK all my adult life (since age 13), never paid US tax, never worked in the USA, never paid into their system, social security etc. I don't use their highways or hospitals, i won't even get unemployment benefits. I am dual citizen because of the fact that I was born in the USA.
> 
> Having said that i don't want to make a quick decision. Generally it's always good to have citizenship in more than one country. That's why I am giving it until the 2016 return to decide. The rules might even change and be more friendly to expats. I think the rules should distinguish between American citizens working abroad temporarily and those that are based overseas permanently with a second citizenship. Those that are genuinely Accidental Americans should be exempt from a lot of this reporting. I know that's unlikely to happen but it would be a fairer system.


If you have little or no contact with the US, you are free to continue ignoring this, at least for the time being. If your UK bank has threatened to report you under FATCA because it knows of your US birthplace, then you may with to at least file FBAR/FinCEN forms. Otherwise, the US doesn't know that you exist, and you may want to keep it that way for as long as you can.


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## celticweb

Hello
I agree with what you wrote but it’s not just about services. It’s about living your life free of fear. It’s about having a normal life without fear of having your bank account closed, your hard earned money taken away with penalties. There is no representation of US citizens abroad. Isn’t that against the constitution? 
It’s the middle classes that suffer, the very rich can defend themselves and the very poor have nothing to take.

Now that I know I will find it very hard to ignore and prefer to get my affairs in order. 
I am honest hard working person paying my taxes in the UK yet I am made to feel like a criminal just because I didn’t know about some filing rules that in no way I would be able to find out about in my every day life as a UK citizen. And I risk severe penalties for this failure completely unproportional to the crime, it’s not even a crime this failure to know. I would renounce in order to live a life free of fear without worrying about compliance and the fear of making a mistake and not understanding the rules or even the cost of the compliance. I have been told by accountants I spoke to that I will owe no US tax so all this fear, stress, expense just to be told I owe no tax.

If it’s just a case of filing some papers, I would not care but compliance is so much more and the risks and penalties appear to outweigh the benefits I receive from US citizenship.

I would be very sad to renounce, it’s not what I would choose to do but the US government is forcing me to make this decision eventually. It seems to me with their aim to catch real tax evaders, ordinary hard working citizens are being caught in the net. 

Still I am going to follow the advice here, take a deep breath, relax, go through the process, try not to let it affect my health and mental health and decide when I can look at this less emotionally.


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## Nononymous

celticweb said:


> If it’s just a case of filing some papers, I would not care but compliance is so much more and the risks and penalties appear to outweigh the benefits I receive from US citizenship.


Before you lose sleep and/or weight, do you know for a fact that penalties against you would be collectible in the UK? 

Canadian citizens in Canada cannot be touched by the US, either for FBAR fines or tax debts, under the Canadian government's interpretation of the tax treaty. So if you have no US income or assets, the IRS can huff and puff all it wants... but can't do a thing to your money. I find that to be a great comfort, though I still prefer to stay off the radar. Canadian banks have never collected place-of-birth or citizenship information and their FATCA compliance efforts seem quite minimal. 

The UK situation might be different. But still, relax...

If you owe no tax, the penalty for filing late (or not at all) is a percentage of zero. So unless you are planning to renounce, you might find a happy compromise in skipping the streamlined procedure and just sending in your FBAR/FinCEN forms (with ballpark estimates if accurate figures are difficult to find) since those are the only things that could theoretically cause penalties - though this has apparently never happened to ordinary non-criminals. Then you'd be covered if your bank ratted you out under FATCA.


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## maz57

BBCWatcher said:


> Wait a minute. The United States federal, state, and local governments provided you a great many benefits (publicly provided goods and services) for "only" the first 13 years of your life. You know, "only" the second most governmentally expensive part of a typical lifetime, after old age. That's not nothing! The U.K. didn't incur those considerable expenses.
> 
> That said, tax systems are not fee for service systems. If they were, then 11 year olds would be paying taxes, too. But of course it doesn't work that way because most 11 year olds cannot pay taxes.
> 
> The U.S. government and its democratically elected representatives have decided that if you want to hang onto a U.S. passport then you might owe a bit of U.S. tax if you both (a) have some rather significant financial success (or better); (b) are not contributing tax revenues to your country of residence at a level equal to or greater than what you would in the U.S. This is a very straightforward deal, and it in part reflects the reality that children are different from adults. Don't like that deal? Then pay $2350 and renounce U.S. citizenship -- still a great deal less than U.S. taxpayers spent on you for your first 13 years. That seems like a _very_ fair deal to me, or at least I don't think too many people in the United States would find your situation "unfair."


Ho-hum. There you go again with the same old lame arguments. The people are not there to serve government, the government is there to serve the people. Besides, we can assume that this child didn't come into the world with no parents. (You know, the annoying people who were actually paying federal, state, school, property, gas, sales, excise, and God knows what other taxes during the13 years before they moved out of the US.) 

The United States is the only country which hounds its citizens to the ends of the earth for life; every other country has figured out that it is stupid, unfair, and unenforceable. And you make it sound so easy to get rid of US citizenship if you don't like it. First of all you need to get an appointment at the Consulate, the supply of which the government purposely limits in order to prevent people from renouncing. Second, you need US$2350, not something that everyone can afford. Thirdly you not only need to file 5 years of back returns plus the current year, you need to run the exit tax gauntlet, i.e. potentially pay "exit" tax on assets that were never in the US in the first place. (Its not likely a 13 year old left the US with much in the way of assets, remember?) Its not a fair deal. Its a raw deal for a person to have their right of return taxed and regulated away by a government and a tax system that purports to treat everybody "equally" by assuming everyone lives within the borders of the US and is subject only to the US tax code.

Besides, the several million who move INTO the US every year and start working and start paying US taxes should easily offset whatever paltry revenue the US collects via its pathetic CBT system. And by the way since you seem to be so keen on exact accounting, is the US government proposing to pay all those newcomers (or their previous governments) for all the education and assets they bring with them from the old country when they move to the US?...I didn't think so.

At least I can agree with your last sentence that not many in the US would think it is "unfair". That's because the many don't think anything about it at all; most in the US don't have a clue how the US is systematically attacking its expats and making their financial lives next to impossible.


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## Bevdeforges

Just to clarify a couple of things - when I referred to future benefits, I was referring to US Social Security, IRS and 401K retirement accounts and the like. If I were to renounce, those payments would be hit with a flat 30% withholding/tax rate, which is significantly more than what I will have to pay if I just declare it as a citizen and get on with life. France is real good about not charging me extra tax on that sort of income and the method of reporting it so as not to be double taxed is quite straightforward.

OK, if you have given your bank or brokerage house a W-9 or even just your US SSN, then the IRS will (probably) know about investment income from those accounts, and at some point in the future, may be able to work out your other sources of income if they receive more detail on your bank accounts than they are getting at the moment. (Currently, they only get y/e balance information from the banks.)

But what Nononymous says is right - they have little or no power to pursue you to seize your money or assets unless you have accounts or assets in the US. That's where the whole "assessment of your personal level of risk" comes in.
Cheers,
Bev


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## celticweb

Hi
i don't know if the UK will enforce the collection of any penalties. Don't the UK and USA have a special relationship? i was told i would not owe any US tax or very little tax. i didn't sell a principle home (that would have triggered tax) or anything else like that. however to get to that point, sounds like a convoluted jiggling of tax credits to figure it out.

i am worried about the penalties for the fbar and I was advised quiet disclosure wasn't a good option because they could assess penalties. I have worked very hard for what I have and worked my whole life and managed to save decent amount of money so it's a huge worry for me. But none of these accounts are hidden, they are part of my every day life as UK citizen banking in my neighborhood.

So i have fear of filing and what will happen or fear of not filing and looking over my shoulder for the rest of whole life. i chose the first option and will see what comes of it. Probably nothing but it still doesn't lessen the anxiety mainly the anxiety of the unknown.


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## iota2014

celticweb said:


> Hi
> i don't know if the UK will enforce the collection of any penalties. Don't the UK and USA have a special relationship?


The UK doesn't enforce collection.



> i was told i would not owe any US tax or very little tax. i didn't sell a principle home (that would have triggered tax) or anything else like that. however to get to that point, sounds like a convoluted jiggling of tax credits to figure it out.


Try the free/cheap tax software, see what it produces and that should help.



> i am worried about the penalties for the fbar and I was advised quiet disclosure wasn't a good option because they could assess penalties.


. 

If you decide on quiet disclosure rather than streamlined, do the tax returns first, making sure you include any interest from the bank accounts, and answer "Yes" to any question about whether you have foreign bank accounts (on Schedule B, I think?). Having done the tax returns, you can then file the FBARs using the "Delinquent FBAR Submission Procedures" (https://www.irs.gov/Individuals/International-Taxpayers/Delinquent-FBAR-Submission-Procedures). Note the statement on that page:



> *The IRS will not impose a penalty for the failure to file the delinquent FBARs if you properly reported on your U.S. tax returns, and paid all tax on, the income from the foreign financial accounts reported on the delinquent FBARs, and you have not previously been contacted regarding an income tax examination or a request for delinquent returns for the years for which the delinquent FBARs are submitted.*


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## JustLurking

Bevdeforges said:


> ...If I were to renounce, those payments would be hit with a flat 30% withholding/tax rate, which is significantly more than what I will have to pay if I just declare it as a citizen and get on with life.


Then the UK does better than France in this regard. The US/UK tax treaty rate on pension payments from the US to non-resident aliens -- and this would include former US citizens -- is 0%, with the UK having taxing rights for payments from non-UK pensions to UK residents. Also, the first 10% of foreign pension payments are tax free in the UK.



CelticWeb said:


> Don't the UK and USA have a special relationship?


Only UK politicians say 'special relationship' with a straight face.


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## Pro.wolf

celticweb said:


> So i have fear of filing and what will happen or fear of not filing and looking over my shoulder for the rest of whole life. i chose the first option and will see what comes of it. Probably nothing but it still doesn't lessen the anxiety mainly the anxiety of the unknown.


I know exactly how you feel, I am in the same boat- due to my completely stupidity (I say stupidity because I had no clue of my tax obligations as us citizen living abroad until a few months ago nite: I don't think the rules make sense but are the rules). I have done the streamlined offshore filing and I just hoping for the best (and hope the CPA completed the forms correctly, I was sure to provide all information to him, even my 0.12 cents interest for one acct). 

But will not be 100% relax, IRS has 6 years to audit any filing (but believe is the same time for Canada. C'est the vie! (I am saying that just to make me feel better and maybe be able to sleep again)


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## Lulu78

iota2014 said:


> The UK doesn't enforce collection.


Does anyone know if Australia and/or NZ enforce collection? 

I tried to read the IGA agreements but I can't really make sense of it :-(


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## iota2014

Lulu78 said:


> Does anyone know if Australia and/or NZ enforce collection?
> 
> I tried to read the IGA agreements but I can't really make sense of it :-(


It wouldn't be in the IGA, that's about information, not tax. Read the Treaty for a country (plus later protocols, letters, etc) to see what's agreed about mutual assistance/collection.

The US only has Mutual Collection Agreements with five countries: Canada, Denmark, France, the Netherlands, and Sweden. That's according to the IRS. It seems a little unclear whether those countries agree. Canada, at any rate, seems to think it _doesn't _ enforce collection of US taxes from Canadian citizens.


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## Nononymous

iota2014 said:


> The US only has Mutual Collection Agreements with five countries: Canada, Denmark, France, the Netherlands, and Sweden. That's according to the IRS. It seems a little unclear whether those countries agree. Canada, at any rate, seems to think it _doesn't _ enforce collection of US taxes from Canadian citizens.


My possibly inexpert understanding of the US-Canada tax treaty is that (1) if you were a US citizen only, living in Canada, the Canadian government would assist the US with collection, and (2) if you were a dual citizen living in Canada but had debts incurred before becoming a Canadian citizen, the Canadian government would assist the US with collection of those debts only. Otherwise nothing - there is no Canadian government assistance to collect any tax debts owing the US incurred by a Canadian citizen.

Furthermore, FBAR/FinCEN fines are considered an administrative penalty not covered by the treaty, ergo the Canadian government will not assist the US with any collection of those, period.

So as long the current regime stays in place (who knows, maybe that's a big "if" these days) the US cannot touch one cent of a Canadian citizen's money in Canada. No reason to lose sleep, in my view.


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## Pacifica

It’s s. XXVI A (8)(a) of the Canada-US Tax Treaty.

"XXVI A. Assistance in Collection

8. No assistance shall be provided under this Article for a revenue claim in respect of a taxpayer to the extent that the taxpayer can demonstrate that

(a) where the taxpayer is an individual, the revenue claim relates to a taxable period in which the taxpayer was a citizen of the requested State, and

(b) where the taxpayer is an entity that is a company, estate or trust, the revenue claim relates to a taxable period in which the taxpayer derived its status as such an entity from the laws in force in the requested State."

And as Finance Minister Flaherty mentioned in 2011, Canada Revenue Agency doesn’t assist in FBAR collection against anyone (whether Canadian citizen or not), as that is not covered in the treaty.


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## Bevdeforges

JustLurking said:


> Then the UK does better than France in this regard. The US/UK tax treaty rate on pension payments from the US to non-resident aliens -- and this would include former US citizens -- is 0%, with the UK having taxing rights for payments from non-UK pensions to UK residents. Also, the first 10% of foreign pension payments are tax free in the UK.


The UK tax treaty is a little bit different in this regard. Generally speaking, it's the UK that gets to tax US citizens on pension payments from the US. In France (and many other countries with tax treaties with the US) it's the country of origin of the pension (generally, just government pensions) that gets taxing rights.
Cheers,
Bev


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## BBCWatcher

celticweb said:


> There is no representation of US citizens abroad. Isn’t that against the constitution?


No, that's the U.K. that cuts off the voting rights of its long-term overseas residents. The U.S. provides you with full and equal voting rights.

With respect to your comments about the middle class versus the wealthy, you've got it completely backwards. As J.K. Rowling has pointed out, wealthy Britons often establish residence outside the U.K. and avoid most or all U.K. taxes, leaving the middle class in Britain with huge tax burdens such as 20+ percent VAT rates. Wealthy Americans cannot do that (if they want to remain Americans) while genuinely middle class Americans can. Yes, middle class Americans have to submit some paperwork establishing that they are, indeed, middle class to get that zero tax deal, but most Americans have to file substantially similar paperwork every year.


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## Lulu78

BBCWatcher said:


> No, that's the U.K. that cuts off the voting rights of its long-term overseas residents. The U.S. provides you with full and equal voting rights.
> 
> With respect to your comments about the middle class versus the wealthy, you've got it completely backwards. As J.K. Rowling has pointed out, wealthy Britons often establish residence outside the U.K. and avoid most or all U.K. taxes, leaving the middle class in Britain with huge tax burdens such as 20+ percent VAT rates. Wealthy Americans cannot do that (if they want to remain Americans) while genuinely middle class Americans can. Yes, middle class Americans have to submit some paperwork establishing that they are, indeed, middle class to get that zero tax deal, but most Americans have to file substantially similar paperwork every year.


Here we go again! BBC, a lot of us don't consider ourselves Americans & for some of us (like myself), I never have & unlikely I will either.
Hypothetical & phyosophical arguments aside, my husband is certainly not burdened by his UK citizenship, as much as I am (& our household) is burdened by my US citizenship. 
In fact we consider his UK citizenship an asset because it opens up Europe for us!


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## Lulu78

While my US citizenship is causing us a lot of anxiety! & $$


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## celticweb

Regarding further comments above about quiet disclosure vs streamlined. every single tax account (except one) said to me to use the streamlined program and especially if renunciation is an option in future. I was told the danger with adopting the so called "quiet disclosure" approach is that the IRS are clear that they want people to bring their affairs up to date using the streamlined procedures. 

I will owe little or no tax so penalties won't come into it with filing, it's more Fbar penalties making me lose sleep. there just doesn't seem to be a good option whatever you do. 

Regarding my comment re the rich, poor, middle class, what i meant is in the event of facing penalties, the very rich have the money and means to defend themselves as they do in all areas of life and penalties won't wipe them out. the poor have nothing to take, it's the middle classes that could be left ruined with all their hard earned money taken away. and all this income was earned abroad and taxed abroad. yes i know it's unlikely but it's still a possibility. Whether or not the UK aid the USA goverment in taking the penalties, i don't know for certain. I would hope to think the IRS have bigger fish to fry.

and my US citizenship right now is causing me a lot of turmoil and anxiety. I hope that once back in the system this might change otherwise i will have no choice but to quit the club.


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## iota2014

celticweb said:


> I will owe little or no tax so penalties won't come into it with filing, it's more Fbar penalties making me lose sleep. there just doesn't seem to be a good option whatever you do.


If you decide to file Streamlined, you won't be hit with any FBAR penalties (assuming you haven't knowingly committed any crimes).



> *A taxpayer who is eligible to use these Streamlined Foreign Offshore Procedures and who complies with all of the instructions outlined below will not be subject to failure-to-file and failure-to-pay penalties, accuracy-related penalties, information return penalties, or FBAR penalties.* Even if returns properly filed under these procedures are subsequently selected for audit under existing audit selection processes, the taxpayer will not be subject to failure-to-file and failure-to-pay penalties or accuracy-related penalties with respect to amounts reported on those returns, or to information return penalties or FBAR penalties, unless the examination results in a determination that the original tax noncompliance was fraudulent and/or that the FBAR violation was willful.


Just make sure that when you file the FBARs, you follow the IRS Streamlined instructions and choose the correct reason for late filing from the dropdown list of possible reasons.



> On the cover page of the electronic form, select “Other” as the reason for filing late. An explanation box will appear. In the explanation box, enter “Streamlined Filing Compliance Procedures.”


The Streamlined instructions are at https://www.irs.gov/Individuals/Int...-Taxpayers-Residing-Outside-the-United-States


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## iota2014

iota2014 said:


> The UK doesn't enforce collection.


See DMBM560230 - Debt and return pursuit: foreign cases: Mutual Assistance in the Recovery of Debt (MARD) (non-EU countries): scope of the MARD provisions
to read about the UK's *current* position on assisting foreign countries with collecting foreign taxes from UK residents. Note that MOU stands for Memorandum of Understanding and MOA stands for Method of Administration.



> *Countries outside the EU which have ratified the CoE/OECD Convention with which the UK has an MOU/MOA*
> 
> Norway, Iceland and the Faroes.
> [..]
> 
> *Countries with which the UK has a DTA containing debt recovery provisions and an MOU/MOA*
> 
> New Zealand, the Faroes and South Africa.
> [..]
> 
> *Additional countries
> *
> As and when additional countries either ratify the CoE/OECD Convention or include mutual recovery assistance in bilateral international agreements with the UK, this guidance will be updated.
> [..]


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## JustLurking

Bevdeforges said:


> The UK tax treaty is a little bit different in this regard. Generally speaking, it's the UK that gets to tax US citizens on pension payments from the US. In France (and many other countries with tax treaties with the US) it's the country of origin of the pension (generally, just government pensions) that gets taxing rights.


Sure. It's just that you gave the treatment for NRAs in France, yet as a UK resident the OP would see entirely different tax rules due to the US/UK treaty.

If tax on a pension is to be a factor for the OP when deciding whether or not to renounce, it would be best for them to decide based on specifics rather than on generalities or on conditions in other countries that will not apply.


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## iota2014

JustLurking said:


> Sure. It's just that you gave the treatment for NRAs in France, yet as a UK resident the OP would see entirely different tax rules due to the US/UK treaty.
> 
> If tax on a pension is to be a factor for the OP when deciding whether or not to renounce, it would be best for them to decide based on specifics rather than on generalities or on conditions in other countries that will not apply.


Bit of confusion here I think. The OP said upthread she's not entitled to a US SS pension, so that's not a factor for her I believe Bev was talking about her own future SS - explaining her own reasons for _not_ renouncing.

The UK treaty is very clear about cross-border social security, less clear about non-cross-border (UK State pension paid to a US citizen resident in the UK).


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## celticweb

Hi
i have no problem paying any taxes if any are due and I am told my taxes will be nil or very little. It is the Fbar penalties I am worried about and that isn't tax, that is a penalty for failure to know the reporting rules and yes definitely not willful on my part. i would like to see them prove otherwise with my background and history which is very straightforward being an Accidental American.

I would have had to be insane to have known about the Fbar and not filed the fbar especially because of these penalties. I am sick with worry now. Also after having such kind advise here, i investigated the website and it is so easy to do. Truly wish I had known.

I don't have a complicated situation, everything has been taxed at a higher rate, i didn't sell a house. it is whether or not i can be bothered to keep up with the compliance afterwards and worry about new rules and keeping up. I would feel very sad to lose US citizenship and hope it doesn't come to that.


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## ForeignBody

celticweb said:


> I would have had to be insane to have known about the Fbar and not filed the fbar especially because of these penalties. I am sick with worry now.


Look again at what Iota gave you in post # 50. Under the Streamlined Procedure you will not be liable to FBAR penalties.


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## celticweb

yes i will most likely be going streamlined. i am going to use a tax accountant because i am just too stressed with it all and don't trust myself to do this without errors. and I have to wait and do fbar at the same time so they can match my return to the fbar. i have excellent tax records so at least i am not chasing UK paperwork.

I think the reason the IRS prefer us to use this program rather than quiet disclosure is to collect data and brag how it's working bringing people forward. so IRS can say we brought such and such amount of people into compliance with this program etc.


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## iota2014

celticweb said:


> yes i will most likely be going streamlined. i am going to use a tax accountant because i am just too stressed with it all and don't trust myself to do this without errors. and I have to wait and do fbar at the same time so they can match my return to the fbar. i have excellent tax records so at least i am not chasing UK paperwork.
> 
> I think the reason the IRS prefer us to use this program rather than quiet disclosure is to collect data and brag how it's working bringing people forward. so IRS can say we brought such and such amount of people into compliance with this program etc.


Yep.


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## Lulu78

Hi celtic; I read your post and I see you going through exactly the same emotions I went through when I found out about my US taxes; worry, frustrations, anxiety, then some more worry & frustration (Am I doing the right thing here? etc.). 

I have done a bit of research regarding the Streamline Vs Quiet disclosure (QD). I really don’t understand why it’s called QD, it’s just your old-fashioned, “garden variety”, ordinary late returns. 
QD remains the only option for a lot of people who are (un)fortunate not to meet the eligibility for the SFOP! Remember for the SFOP, you do need to spend 330 days per year (for the most recent three years) outside of the US i.e. no holidays in the US exceeding 35 days. Anyone, had there nice long summer vacation render them not eligible for the SFOP?! I imagine quite a few! 

Now, with the SFOP, those were my concerns;

1.	There is no pre-clearance process, you don’t know if you will be accepted or rejected, and if you did somehow find out that you have been rejected then you can’t appeal the decision anyway 

2.	You have to complete this “creepy” non-wilful certificate (form 14653); which the IRS tell you to include “the whole story including favorable and unfavorable facts”. What does that even mean? (Read the 14653 form first, and decide if you are comfortable with it, I think it will be what makes or breaks your decision to go streamline.)

3.	Back to the certificate, what is non-wilful anyway? What about wilful blindness? It’s a whole can of warms that is apparently determined by case law, and I am personally not prepared to fork out further money for a lawyer to help me complete my certificate! Or should I just to be safe?

4.	Will sending the forms via the SFOP mean it will make it easier for the IRS to scrutinise them? Particularly as they mentioned that each non-wilful certificate will be reviewed by an IRS agent. While with the ordinary late returns (QD), the IRS will have to sift through a lot of papers and therefore they may not receive as much scrutiny/attention? 

I think for certain people (perhaps you and I), it doesn’t really matter which way we go (can someone correct me if they think otherwise). Because either way, if we don’t owe any money, no US based assets (for the IRS to get their hands on), then there should be no FBAR penalties whichever method of filing we choose? 
“The IRS will not impose a penalty for the failure to file the delinquent FBARs if you properly reported on your U.S. tax returns, and paid all tax on, the income from the foreign financial accounts reported on the delinquent FBARs, and you have not previously been contacted regarding an income tax examination or a request for delinquent returns for the years for which the delinquent FBARs are submitted.” 

I am leaning toward the SFOP at this stage (although I keep flip flopping depending on my level of anxiety), because that “creepy” certificate will give me the opportunity to spell out to the IRS “hey, I don’t live in the US, haven’t been there for over a decade, and if you added up all my US time, then it adds up to less than 2 years of my life. All my income is earned in the land down under, and fully taxed and the tax paid for here (on time), and I am a law abiding citizen and always have been (until you turned me into a tax criminal and a tax evader, well maybe I won’t say that last bit but I will be thinking it ;-)).


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## iota2014

Hi Lulu78 - 

My guess - I don't think a Streamlined submission would be likely to get rejected as long as it fits the stated criteria. There would have to be a reason for the rejection, and presumably a letter stating the reason and telling the person the outcome.



> .	Will sending the forms via the SFOP mean it will make it easier for the IRS to scrutinise them? Particularly as they mentioned that each non-wilful certificate will be reviewed by an IRS agent. While with the ordinary late returns (QD), the IRS will have to sift through a lot of papers and therefore they may not receive as much scrutiny/attention?


Best to assume everything will be scrutinised, just for your own peace of mind. They're not likely to waste scarce time and resources on a "foreign" submission if there's nothing that attracts attention.



> I am leaning toward the SFOP at this stage (although I keep flip flopping depending on my level of anxiety), because that “creepy” certificate will give me the opportunity to spell out to the IRS “hey, I don’t live in the US, haven’t been there for over a decade, and if you added up all my US time, then it adds up to less than 2 years of my life. All my income is earned in the land down under, and fully taxed and the tax paid for here (on time), and I am a law abiding citizen and always have been (until you turned me into a tax criminal and a tax evader, well maybe I won’t say that last bit but I will be thinking it ;-)).


I know how you feel -I feel the same - but I definitely don't think it's a good idea to tell them about it, and certainly not on a Streamlined certification form signed under penalty of perjury. That's just asking for trouble - especially if you are considering renouncing. Much better to jump through the hoops and get cleanly out of the system, that's how I see it at least.


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## Lulu78

Thanks iota2014 
I was kidding about the last bit. I will most definitely be very polite & diplomatic when asking for amnesty in my 14653


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## maz57

No point in trying to be a "hero" by making a scathing statement. The IRS and State Dept. already know all about it anyway (you know, the old don't ask, don't tell). Just hold your nose, jump through the hoops, and get out ASAP. 

Once you are free you can tell people who actually care which is NOT going to be any US government official. That's how we wound up in the present sorry state of affairs in the first place.


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## iota2014

iota2014 said:


> See DMBM560230 - Debt and return pursuit: foreign cases: Mutual Assistance in the Recovery of Debt (MARD) (non-EU countries): scope of the MARD provisions
> to read about the UK's *current* position on assisting foreign countries with collecting foreign taxes from UK residents. Note that MOU stands for Memorandum of Understanding and MOA stands for Method of Administration.


I bolded the word "current" because you never know what changes in policy may be just around the corner - especially nowadays, with UK politicians falling over themselves to publish their (carefully edited) tax returns and pledge greater transparency. You wouldn't think they're the same bunch that were howling with outrage a couple of years ago over the publication of their tax-paid expense claims.

Guardian blog piece:
Should we bite the bullet and all post our tax returns online? | Money | The Guardian

If the UK were to adopt this practice, the IRS would have access to the income details of US citizens resident in the UK. Collection agreements might well ensue.


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## Bevdeforges

Hey, according to this week's Economist, Norway posts ALL tax forms online and gives the public a right to look up anyone's tax returns they want! It's only recently they stopped allowing folks to look up other people's returns anonymously - so I suppose there would be some advantage if you at least knew whether the IRS had been looking at your returns or not. (I'm sure they have much better things to do with their time than to scour foreign tax postings for Americans - who would not be identified as such in the foreign tax base.)
Cheers,
Bev


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## iota2014

Bevdeforges said:


> Hey, according to this week's Economist, Norway posts ALL tax forms online and gives the public a right to look up anyone's tax returns they want!


Exactly. That's what the Guardian article is about - whether the UK should follow Norway's example. 



> I'm sure they have much better things to do with their time than to scour foreign tax postings for Americans - who would not be identified as such in the foreign tax base.


That certainly wouldn't be cost-effective. Checking for a UK-resident US citizen's foreign income return, as a step in the processing of the person's 1040, would be logical, and easy. And the point is, having access to income details allows the IRS to build a case, whereas without those details it's much harder for them to prove money is owed.

It may never happen though, especially if the UK stays in the EU.


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## Bevdeforges

iota2014 said:


> Checking for a UK-resident US citizen's foreign income return, as a step in the processing of the person's 1040, would be logical, and easy. .


How would that be any easier for US citizens resident in the US than in, say, Norway?

There is no indication of nationality on most tax forms I've ever filled out. And certainly no US SSN. The IRS really does function largely on SSN, not name. I think it would be hard to link US taxpayers to their foreign tax returns.
Cheers,
Bev


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## iota2014

Bevdeforges said:


> There is no indication of nationality on most tax forms I've ever filled out. And certainly no US SSN. The IRS really does function largely on SSN, not name. I think it would be hard to link US taxpayers to their foreign tax returns.


It would be extremely easy - IF the UK decided to put up the database and IF the UK agreed to allow the IRS to access it. Big IFs, but then not so long ago FATCA and the IGAs would have seemed extremely unlikely.

It would only need a slight change in the forms and instructions, to require taxpayers filing from abroad to provide their local tax ID.

I didn't post the comment to cause unnecessary alarm - only to emphasize that the information I posted previously, about the lack of a UK-US collection agreement, could easily change, so people might be wise to bear that possibility in mind.


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## Bevdeforges

To be honest about it, the US and many countries already exchange tax data for taxpayers where there is an ongoing audit or questions about improprieties. But most governments are mostly concerned about their own taxes and they aren't likely to want to muck up their tax forms with questions about "foreign tax i.d. numbers." (When the US asks for foreign tax numbers, I always answer "n/a" because frankly in France we don't have a tax i.d. number.) 
Cheers,
Bev


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## iota2014

Bevdeforges said:


> To be honest about it, the US and many countries already exchange tax data for taxpayers where there is an ongoing audit or questions about improprieties.
> 
> 
> 
> Yes, the US-UK treaty provides for exchange of information. It has to go through the Competent Authorities, though, which no doubt makes it expensive, so as you say, it's not done routinely.
> 
> 
> 
> 
> But most governments are mostly concerned about their own taxes and they aren't likely to want to muck up their tax forms with questions about "foreign tax i.d. numbers."
> 
> 
> 
> It would be the IRS that would be asking for the UK-resident US Person's UK tax ID.
> 
> 
> 
> 
> (When the US asks for foreign tax numbers, I always answer "n/a" because frankly in France we don't have a tax i.d. number.)
> 
> Click to expand...
> 
> Really? That's interesting.
> 
> Edit. The OECD thinks you do. https://www.oecd.org/tax/automatic-...nce/tax-identification-numbers/France-TIN.pdf
> 
> Click to expand...
Click to expand...


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## Bevdeforges

Hm, I will have to continue with my policy of giving only my US SSN to the IRS and only the appropriate French tax numbers to the Fisc. And never the twain shall meet.
Cheers,
Bev


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## iota2014

Out of curiosity, do French politicians publish their tax returns?

I believe David Cameron is the first UK Prime Minister to do so. Be interesting to see if it becomes the norm.


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## Bevdeforges

iota2014 said:


> Out of curiosity, do French politicians publish their tax returns?
> 
> I believe David Cameron is the first UK Prime Minister to do so. Be interesting to see if it becomes the norm.


No - but when Hollande took office there was a big push on for the members of the government to publish their personal balance sheets - assets owned and major debts. But, in typical French fashion, some did, others didn't. 

When these scandals like the Panama Papers break here, there are inevitably one or two name French politicians with accounts that are mentioned. Nothing much ever seems to come of it, though.
Cheers,
Bev


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## maz57

I can understand why the public might be interested in the tax returns of their politicians, but I also think that publishing those returns is taking it a bit too far. Tax returns are, after all, private information. To then turn around and publish them on the internet for all to see makes no sense. Its more of the same old "if you have nothing to hide then why do you have a problem?" nonsense.

If you assume that it is in the public's interest to attract the best and the brightest to public service, then requiring unnecessarily invasive publication of their private affairs isn't going help that interest. Smart, capable people looking to serve accept that they must take a pay cut compared to what they could make or were previously making in the private sector. If they must then also sacrifice their right to any privacy at all then the pool of willing, well qualified people is going to be further reduced. What's next, publishing a list of every sexual partner they have ever had since puberty? Potential politicians, like the rest of us, are generally not going to be perfect. They live in enough of a goldfish bowl as it is.

If we make it too onerous to serve in public life, no rational, capable person will choose to serve leaving only the not so rational, not so capable, and not so bright people (who don't mind having their1040EZ out there for all to see) to fill the void. When you consider what is presently going on in the world we may have reached that point already.


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