Shulman won’t accept a 2nd term (Did anyone really ask him to stay?)

IRS Commissioner Douglas Shulman, on Thursday (April 5), in a question and answer session at the National Press Club in Washington, indicated he would step down when his term expires in November. As we have all heard before, he repeates the numbers of how many have come forward  (33,000) and how much they have collected ($4.4 billion).  Yawn, yawn.  And particularly offensive is the following:

We view offshore tax evasion as an issue of fundamental fairness. Wealthy people who unlawfully hide their money offshore aren’t paying the taxes they owe, while schoolteachers, firefighters and other ordinary citizens who play by the rules are forced to pick up the slack.

His entire speech is at the IRS newsroom.

One of the first sites I visit everyday is Jack Townsend’s Federal Tax Crimes Blog. And not surprisingly, he has written about Mr. Shulman. (emphases mine):

I wonder if the Commissioner really understands how misfocused the program really is.  Does he really understand the difference between whales and minnows, both of which he sweeps into the same net?  Punishment should not be the same for both.  Yet, the IRS offers a program of one size fits all, where the penalties for the whales (most of whom are really bad guys in terms of tax noncompliance) and the minnows (most of who are not).  I am sure that the Commissioner and the IRS see the opt out as the safety valve as the way to deal with minnows and nuance, so that the inside penalties really apply to only on the bad guys.  But the opt out because of all its uncertainties and interminable delays poorly serve a community of taxpayers who should receive at worst a light tap on the wrist and who are willing to be compliant into the future now that they are fully educated about the expectations of the IRS.

I strongly urge the IRS to move swiftly to publish guidance for how taxpayers will be treated on the opt out audit.  That guidance should not cover the whales — who are the ones likely to deserve the onerous penalties and should stay within the program penalty structure without opting out.  The guidance should make the punishment fit the conduct — I don’t say crime because in these cases there is no crime.  That would mean in many, perhaps most, cases a future compliance (some call it a warning) letter or a relatively light slap on the wrist and at least an implicit welcome into the community of taxpayers with full knowledge of what is expected in this area.  This would help alleviate a lot of the angst that these good people have about entering the program and getting right with the IRS.  That way, these taxpayers can feel more comfortably about opting out in the first place and, because they will know something about the administration of the opt out audit, will not feel that for long  periods they have the Sword of Damocles hanging over them.

One of the commenters to this post relays yet another horror story about what he/she is experiencing in OVDI.

Anon5% Apr 6, 2012 12:16 PM

The IRS OVD programs, for those of us in the know, appear to be the equivalent of letting the Keystone Cops loose in the Treasury Department.

What irks my ire most about Commissioner Shulman’s remarks is that the hallmark of a true leader is seriously missing. It would not take much to acknowledge the missteps with respect to minnows in the OVD programs by implementing a clear policy for rectifying the situation. Nothing needs to be said. The policy would speak for itself. This kind of action is seriously lacking. An action of this sort would allow the Commissioner to save face as well as help many victims of the poor policy planning.  Let me illustrate by example.

As a minnow, I have recently had to abandon my legal counsel because I wish to opt out and I can no longer afford them. They have told me their costs will be greater than my penalty. In our last conversation, my former lawyer told me that people like me, minnows, were suffering greatly since a “one size fits all” policy was implemented. He told me that when FAQ 35 discretion had been allowed, he had a client who had USD 300 million in assets overseas and who, in OVDP, faced a fine of USD 60 million. The client spent over USD 100,000 on legal fees and my former lawyers were able to obtain discretion from an IRS agent so that the client paid a penalty of USD 50,000.

If I am not mistaken, Just Me paid a penalty of $25k. This is so unfair it makes my blood boil. I kind of doubt our dear friend has assets of $300 million. Yet the wealthy man paid only double . How on earth could anyone think this is justifiable, reasonable or FAIR?

Another commenter, who I believe is a lawyer offered this:

How about getting an electronic petition going, one of those thingys that you can add your name, address, email, etc, to and edit a standard letter and it gets sent to Commr. Shulman outlining the reasons why this OVD program is silly, unfair and actually serves to undermine tax compliance by highlighting who gets prosecuted and who does not? Occasionally, I sign up for letters to my Senators and Congressmen and I always get a thank you back so I know they got the letter.  I will sign it for sure as will many lawyers, accountants and people who are affected by it. I would not have known much about this program were it not for this blog, but now I know and it infuriates me. This is just a bad idea on many levels. I cant imagine how infuriated those involved in must feel.

Anon’s comments about being a leader point out all that is not noble about people in positions of power in the US government. (I almost said “our”).  A real leader would at least defend himself against the “allegations” made by Ms. Olson in the TAD. He escapes by claiming he is only required to respond to the annual report to Congress. Rather cowardly, don’t you think?

November is 7 months away. Though I doubt Mr. Shulman will get off his horse about his accomplishments regarding offshore tax evasion, it would be interesting to see if we could find a way to insist on a breakdown of who those 33,000 were, as well as try to force some kind of response at least to the FAQ 35 issue.  I would expect, if the American people read about the wealthy man with $300 million paying $50,000 compared to Just Me paying $25k, maybe a few would come around. Somebody should make the Congress and Shulman exposed for what they done.

I wonder if it would be worth trying to set up another petition. The FATCA petition moves slowly and I don’t know if there would be a way to get people interested in another one.



90 thoughts on “Shulman won’t accept a 2nd term (Did anyone really ask him to stay?)

  1. But before his term expires let’s hold his feet to the fire demanding that he confirm that the front-runner in Egypt’s upcoming presidential election, who was born in Egypt to a US citizen mother, and therefore is a US citizen, is totally up-to-date in his US tax obligations and FBAR reports. If not, he should be extradited to the US to stand trial for tax evasion.

  2. I totally agree. Being unfamiliar with him, I googled him and let us do hope he is disqualified:

    Abu Ismail is a candidate for the Egyptian presidential election of May 2012. As of early April 2012, he is considered the front-runner, and enjoys notable displays of popular support.[1][2]

    In foreign policy, Abu Ismail is in favor of ending Egypt’s peace treaty with Israel and has spoken of Iran as a successful model of independence from the United States.[2] His domestic agenda includes opposition to the dominant role of the military in Egyptian politics and Salafi social reforms such as lowering the age of marriage to puberty,[1] or veiling women and segregating them from men in the workplace.[3]

    Iran as a successful model? Social reforms? Good lord………..

  3. I wouldn’t expect any change in U.S. taxation policy with regards to citizenship based taxation. It seems to me that the basis of the agrument is at root “emotive” and not “legal”. The funadmantal question of by what means the extent Congressional spending power can be limited to U.S. jurisdictional boundaries while taxation power isn’t similarly limited is a Constitutional issue that Washington refuses to address in any other terms than one of emotion, eg. patriotism.
    However it seems to me that, both legally and Constitutionally, the two powers are coterminus. In other words the U.S. government’s power to tax cannot extend beyond its power to spend. Taxation and appritopiation are both two sides of the same coin.

  4. @Nobledreamer, Abu Ismail ‘s views could be considdered middle-of-the-road among the Muslim Brotherhood which undoubtetly has strong support in Egypt. If he does not run, he could be replaced by someone with even more extreme views from within that organization who, like Iran, favors the total destruction of Israel.

  5. Many in the Obama administration don’t make it past the first term with him (I am aware Shulman is a Bush appointee). Obama has already had two chiefs of staff–Rahm Emmanuel and Bill Daley–both part of the Chicago machine, both quit before serving to end of the term. Hillary Clinton will not take a second term as Secretary of State. Timothy Geithner will not serve a second term. There are probably others.

    This indicates to me that the problem is Obama. People should wake up and smell the coffee.

  6. @ UncleTell
    I’d like to say it was a good idea but the number of signatures needed is pretty high and the petitions often fade off the first page, out of sight, pretty quickly. Also, giving your name to the Whitehouse might not be such a great idea. I don’t think Obama listens anyway … he just plays a listener on TV.

  7. @all- basically I believe that if the increasing number of people who are willing to dump their U.S. citizenship hasn’t already had an impact then I think that a petition that is signed by a bunch of people, whose vote doesn’t matter anyways, isn’t going to be acknowledged either.

  8. @Roger,

    Yes, of course, you are right from that perspective. I have read about the origins of Al Quaeda and the Muslim Brotherhood and they certainly have evolved to an incomprehensible set of “values.”
    I fear especially for the women of that country.

    I will never understand their position about Israel. Never. I can certainly understand Israel’s concerns and why they would consider striking first. (Not to say I agree). And Ahmedinajad-I cannot believe the UN actually allows him to get up and rant like he does. Let us hope reason prevails and we do not end up seeing this potentially dangerous situation become even worse.

  9. @All

    I didn’t really think a petition would be the way to go. There probably is no way to get the Comm. to own up to what he has really done.

    I wonder if we could get the breakdown (of the 33,000/$4.4bn) by requesting the info via FOIA. I explored it a little last nite but was too tired to piece through and figure it out.

    I just cannot stand the idea that some rich fatcat would not pay more than twice what Just Me had to pay. It’s disgusting.

  10. @all…

    Well, I think I have exhausted the subject on my feelings of Commissioner Shulman and his contributions Tax enforcement. Good riddance. I biggest fantasy is that he someday has to suffer at the hands of his own OVDI program.

    When you see such strong comments by the well known attorney Jack Townsend, who is not known for hyperbole, saying what I have been saying about Minnows and Whales since my first letter to Shulman, I feel somewhat vindicated. At least he adds his voice to a chorus of competent attorneys (with DOJ and IRS background) now speaking strongly which makes me feel that my assessment way back in the beginning was not wrong. Not that it matters anymore. I am sure he will find some good high paying job advising those that are victims of his wonderful programs. That is what they all do.

    Let’s hope that someone who “gets it” about what is wrong with IRS complexity, like a Nina Olson is his successor. Probably not. Carl Levin would filibuster the appointment.

  11. More info has come out in the press in the last couple of days. It appears that Abu Ismail’s mother became a US citizen after he was born. She had a daughter who lived in the US with an American husband which his mother used to visit for extended periods. She apparently was a registered voter in California and it is believed that she used a US passport to enter and depart from the US.

    So Abu Ismail would not himself had US citizenship, but after Mubarek was deposed, the interim government managed to introduce some sort of decree which disqualifies a president being elected who has a parent who has citizenship in or is or was a dual citizen of another country. What they were trying to avoid was an Egyptian coming back home who had lived in the West and becoming a Presidential candidate, but it apparently never occurred to them that a Muslim Botherhood leader like Abu Ismail might be excluded as well.

    All of the smoke has not yet cleared, but some of it has.

  12. @all

    I have been too busy the past few days to really sit down and digest Shulman’s speech. Tonight, I want to see if the National Press Club had any questions to challenge any of his assertions of offshore success. I think I know the answer without watching, but to be fair, I plan to…

    Just reading his speech, this one self described focus of his, says everything you need to know about the OVDI programs…

    ” I’m a believer in relentless and myopic focus on priorities!”

    MYOPIC… Really? That is what you want to celebrate? He is so myopic that he can’t distinguish Whales from Minnows, and yet trumpets this as a “core” belief?

    Frankly, I want someone heading an organization that is just the opposite of Myopic, for god’s sake… I have to get back to work, as this just pisses me off the more I read… grrrrrrrrrrrrrr !!!

  13. @all

    Obviously the next Commissioner will be appointed by Obama. This could be very very interesting. If not done quickly, Romney could make this a campaign issue. If it’s a campaign issue, then OVDI might just get on the radar. Or is this just a fantasy? I have always felt that Romney is the only candidate who might be sympathetic to citizenship-based taxation, OVDI, FATCA, etc.

  14. @Roger

    Maybe the same sort of irony as in ACA fighting so hard to get citizenship for all who were entitled only to have the US gov decide to extend it (later) in the perverse way they have (ex-“relinquishants”)

  15. @renounceuscitizenship- I was thinking the same thing. It seems that his overseas financial accounts are giving him an image problem and I also was thinking that if he became President that he MAY deal with this whole issue.
    I am sure that any successor that Obama appoints will be given the same mandate that Schulman had and will be of the same character. We have to remember that the Commissioner isn’t the problem. The root of the problem resides with the political handlers and years of unchangeable tradition in which the U.S. sees itself as EXCEPTIONAL..

  16. @recalcitrantexpat

    Glad to find a “like minded” person. You probably know that the Romney family has a vacation home in Canada. In addition:

    – Romney spent at least a year living in France as a young man;
    – Romney’s father and Ann Romney’s father were born outside the U.S.
    – I once saw an article that suggested that Romney might have a claim to Mexican citizenship (whether true or not the thought may have crossed his mind)
    – it is clear that Romney has foreign bank accounts (either directly or indirectly) and he obviously is not evading or even avoiding tax
    – he is very business focused which means that he will clearly see the reasons why territorial based taxation will be good for American business
    – I don’t think that it is a huge jump to move from a shift to territorial tax for companies to territorial tax for citizens

    I really believe that he is the only candidate who:

    1. Has the mental ability to put this together; and
    2. Has come into contact with enough of this so that he might just be interested in it
    3. It will give him a point of clear differentiation from Obama on the campaign trail. Now, I know that there are some who might see this as politically risky. But, he will surely get the support of U.S. business if he takes some of these positions.

    I believe his cottage is in Grand Bend Ontario. Maybe the Isaac Brock Society should send him a message from:

    Grand Bend Ontario and the rest of the world!

  17. @renounceuscitizenship- Yes, it is good to find someone else of similar views. The only other two candidates that I would have liked to have seen run are; John Huntsman and Ron Paul. When I listened to Mr. Huntsman discuss his views on the economy and world issues I found him to be the most erudite of all the candidates. Unfortunately for him America is not interested in well thought out policitcal positions that question long held U.S. views. Ron Paul was my second choice because he understands how much of a threat FATCA is to the world economy and he wants to regin in the IRS and the Federal government.
    When it comes to Romney I can only hope that he will see from his own life just how harmful is the U.S. position on extraterritorial taxation and foreign financial account reporting.
    Personally I think that we should have no contact with Romney until after the election. If he is seen as being influenced by U.S. citizens who do not reside in the Staes then he will be associated with helping people evade taxes. Tax evasion is already the line that some are trying to tack on to his foreign bank accounts. Plus he is having enough trouble himself overcoming his past record of laying off people and owning two Cadilllacs etc.

  18. @renounceuscitizenship; No doubt, Mitt Romney indeed is a dual US-Mexican citizen. His father George was born in Mexico to US-citizen parents and Mitt, born outside of Mexico to a Mexican-citizen father was therefore a Mexican citizen at birth. It is not something he would need to claim, because he had it from birth. In this respect Mexican nationality law is simlar to US law. But he does not have to file Mexican tax returns or pay Mexican taxes because Mexico, like most of the countries of the world except the US, practices residence-based taxation rather than citizenship-based taxation.

  19. What could be more effective is filing mass applications for information under (Freedom of information act), asking percentage of minnows residing abroad (i.e. foreign address) in the 33,000 and total penalties collected from minnows.

    This law as some teeth ( see section under ‘Scope’):
    The act explicitly applies only to executive branch government agencies. These agencies are under several mandates to comply with public solicitation of information. Along with making public and accessible all bureaucratic and technical procedures for applying for documents from that agency, agencies are also subject to penalties for hindering the process of a petition for information. If “agency personnel acted arbitrarily or capriciously with respect to the withholding, [a] Special Counsel shall promptly initiate a proceeding to determine whether disciplinary action is warranted against the officer or employee who was primarily responsible for the withholding.” In this way, there is recourse for one seeking information to go to a federal court if suspicion of illegal tampering or delayed sending of records exists.

    It is hard to deliberately ignore few thousand requests from minnows, who are sufferers of this jihad and miss-information. It would become increasingly harder to deliberately evade so many requests and plead ignorance later (if someone fillies a complient).

  20. This information about percent of minnows (in the 33,000) and amount of penalties (in the 4.4 billion) would be a great defensive tool. I am sure IRS doesn’t want to publish that information until they left with no other choice.

    Even after clear warnings from TAD, US ambassador to Canada and many tax-practitioners, this information exposes that the IRS deliberately treated minnows no differently than the real tax-cheats (who live in the USA and deliberately hide money in tax-heavens).

    But we must try to systematically expose IRS’s ‘bait-and-switch’ and show how IRS destroyed the lives of innocent dual-citizens (who owe little or no taxes and not tax-cheats).

    To make quick buck, IRS lost trust of 6 million strong expat community, causing irreparable damage to the US economy in general and exports, tourism in particular. Many of us relinquishing our citizenships and also reduce our visits to the USA. This alone costs billions to tourism industry.

    Each expat structure his investments to avoid US, due to complex regulations, forms and any inadvertent mistake could ruin his life/business. For example, many expat business people working on avoiding US suppliers whenever possible (to avoid falling in the filing trap), since it is impossible to find a tax advisor in our countries. Many of the tax experts didn’t know about FBAR until 2009.

    This OVDI proved that we can’t do business with IRS in good faith: Although we don’t owe any taxes, reasonable cause will not save us from huge life altering penalties (years of uncertainty, distraction from business and huge legal fees). Any dependency or relationships with US suppliers are used by IRS as leverage to extract fines, if one inadvertently missed filing obscure forms.

    None of these acts are wrong or even unethical, since we must avoid people/organizations with whom we can’t deal in good faith, especially when they have all the powers to enforce their will.

  21. @expat_business_man…

    Right you are! But then you are thinking logically, and we have a Commissioner that brags about a pejorative… His Myopic focus.

  22. @Expat_business_man,

    Thanks for the clear summation of the US making a quick buck with us. Truly, many of us feel that we can never again trust what happens with the IRS and it is the main reason we have to renounce or relinquish that extraneous (and toxic, to us) citizenship.

  23. @all

    I refer to part of Jack Townsend’s comment about Mr. Shulman:

    “I wonder if the Commissioner really understands how misfocused the program really is. Does he really understand the difference between whales and minnows, both of which he sweeps into the same net?”

    Let’s pause for a moment and ask if this could be possible? We know that he was once in Toronto to address the ABA. But, other than that, has this man ever been outside the United States? (In any case, a visit to Toronto is not really a trip outside the United States). Does anybody know anything at all about him? I am trying to imagine what kind of background could he have that would allow him to think (or rather not) the way he does?

    Any help would be appreciated.

  24. I used to work for the world’s biggest electronics distributor and we had a General Manager who was corrupt but we couldn’t do anything about it because he always made his monthly sales number (using extremely unethical methods).

    In the end the manager was found guilty of a massive theft from the company but they chose not to prosecute because it would harm the company’s image (ironic). He was escorted out of the building with no warning right before our weekly sales meeting.

    If Shulman is corrupt and that wouldn’t surprise me considering his actions, wouldn’t the government want to hide the fact to protect themselves?

  25. @renounceuscitizenship

    I can tell you a little about the place he comes from which may or may not actually be an accurate assessment of his “makeup.”

    He is from Oakwood, an upper-class section of Dayton Ohio.
    The general perception of people from Dayton is is that Oakwood folks are somewhat more “privileged” than those of us from the rest of the city. Dayton was highly industrial in the ’70’s, when he would have grown up (b 1967). There is a large Air Force Base there, Wright Patterson, which people are proud of as well as other companies who did many contracts for the government (such as Mound/Monsanto, which received many contracts from DOD).
    I would think it accurate to say that patriotism is strong and valued there so that would set a base of trust in the government.

    Shulman holds a Bachelor of Arts degree from Williams College, a Master of Public Administration degree from Harvard University’s John F. Kennedy School of Government, and a Juris Doctor degree magna cum laude from Georgetown University Law Center. None of them slob schools. For someone with his background, it would be hard to imagine that he had never travelled to Europe, etc.

    Of interest, from 1998 to 2000, Shulman was Vice President of Darby Investments, Ltd., a holding company, where he managed financial and legal aspects of the company’s transactions. Darby has more than 100 investments across the investment platform in Europe, Latin America and Asia. He would certainly have come across resident USCs investing abroad. Also of interest is from 1996 to 1997, he was Senior Policy Advisor and then Chief of Staff of the bipartisan National Commission on Restructuring the IRS.

    Maybe a small start to understanding what has made him what he
    is. While I don’t like a lot of what I have learned about policies he has established, I don’t think I would go so far as to say he was “corrupt.” I would actually expect the opposite, that he probably has a strong sense of what “right” is.

  26. Shulman is just another bureaucrat. His interest is in his own career, regardless of who gets squashed in the process.

    The core of the problem really lies with Congress. People like Grassely, the Levin brothers, Rangel and others view today’s expats the same way British Parliament viewed the American colonists — “stop whining and be grateful to be a serf in the empire.”

    The fact that expats don’t use any US government services and pay taxes where they live is irrelevant to such people. Expats have no representation in Congress and are therefore easy targets for predatory legislation.

    1776 is already underway, one RENUNCIATION at a time at a time.

  27. nobledreamer – Thanks for digging out the bio on Shulman. But I cannot give the man a pass. No exoneration for any careerist who inflicts that kind of willful damage. Fancy strings of degrees count for nothing in the realm of axiology. Lots of well-educated have served lots of nasty states. You are what you do. How do I deplore thee? Let me count the circles of hell.

  28. @usxcanada- if you are refusing to give Schulman a pass because you want to deny him access to the, “only following orders”, then I would have to agree with you. This defense didn’t work for the Nazis or for those involved in the My Lai Massacre.
    But your legitimate objection is pointing to a much greater problem, which is how do you demonstrate to a government that is in power that its laws are criminal? This task is the hardest to do and can only be accomplished through a court trial or by moral public suasion. Unfortunately neither of these routes is readily available to expats.
    It took years of public demonstrations before the U.S.government finally got of Vietnam. It also took years of public demonstrations before the Civil Rights movement was able to change things. As we have already said though, there is no one in public office who wants to advance our cause and the American public is under the dellusion that we are traitors to the cause. Even in the face of massive renunciations the U.S. has decided to double down on its anti expat stance rather than to change course.
    Schulman is doing the job that he has been given. If he were to refuse to do it he would just have been replaced with someone else who would.

  29. The only real power expats have as individuals is to renounce / relinquish US citizenship.

    After a while, someone in Washington just might catch on. But I wouldn’t hold my breath on it.

    It took 58,000 dead American soldiers, over a million dead Vietnamese, plus at least 30 years before McNamara (another highly educated bureaucrat) would admit the Vietnam war was a mistake.

  30. My entry above should have read:

    “stop whining and be grateful to be a serf in the empire.”

  31. @recalcitrant

    Great comment, but I don’t agree that in the context of OVDI that Shulman is “just doing the job that he has been given”. The OVDI program is not an Act of Congress it is a program that has been crafted by the IRS. OVDI could have been crafted in a number of different ways. Mr. Shulman had designed and administered OVDI in a way that treats Whales and Minnows in the same way. Furthermore, this is now well known to the IRS. Hence, he is NOT doing the job that he has been given. He has started a war that is now predominately against U.S. citizens living abroad and immigrants. The war is causing deliberate damage to these two groups.


  32. The war against expats and immigrants is just getting warmed up. Wait until FATCA kicks in.

  33. Yes, because Shulman never ever alludes to taxpayers who live outside the US unless in the same breath with the Cayman Islands, tax evasion and tax havens. This is a deliberate and conscious strategy. He knows that the OECD definition of ‘tax haven’ that the US subscribes to does not apply to most countries in the world, and certainly not to Canada. It is dishonest and disingenuous.

    By denying that we have any legitimate concerns, needs for service, and honest reasons to have ordinary bank accounts and financial lives if we aren’t living inside the US – he dodges all concerns about his conduct. We only exist in the context of ‘enforcement’ efforts.

    We citizens outside the US are only ‘taxpayers’ for enforcement and penalty purposes, but not ‘citizens’ or ‘taxpayers’ who are considered worthy of service, or any other constructive and reasonable treatment by the IRS. We don’t rate any ‘services’ in the countries with the largest populations of US citizens ‘abroad’ (Canada and Mexico). We don’t get any ‘education’ efforts, no IRS tax sessions at our embassies, no volunteer preparers to help those with low incomes, or low literacy/numeracy skills outside the US, no toll-free phone numbers, no volunteer committees to gather input and identify gaps in services. You can’t tell me that it would be that costly to send a couple of representatives to Toronto or one of the other major centres like Vancouver. Wouldn’t the ‘education’ and ‘compliance’ functions be better served that way?

    The fact that he never ever mentions Canada specifically, or Mexico, or even any other expat community other than Switzerland and the ‘offshore’ havens is very very telling.

  34. @badger- I hope that you aren’t trying to make an argument for better service because that is not what expats want. Fundamentally it is just plain wrong and illegal for the U.S. to impose its tax laws on an extraterritorial basis. What is called for is a “territorial” tax system. U.S. tax laws serve no purpose for people who are not resident in the U.S. because it is the tax laws of our place of residence that determine the economic life of an expat.
    As for whether or not it would be prohibitively expensive to estbalish IRS tax services in other countries, the truth is that it would. Especially when you consider that there really isn’t much tax to be received under the present tax treaty arrangements that the U.S. has with many countries. I also believe that the IRS does presently send agents out to different embassies during the tax season but of course the problem for the taxpayer is being able to be there when the IRS rep is there.
    What the expat community wants is “residence” based taxation. No more and no less. End of story.

  35. Excerpt from IRS Newsroom cited in this post – April 2012:

    “We view offshore tax evasion as an issue of fundamental fairness. Wealthy people who unlawfully hide their money offshore aren’t paying the taxes they owe, while schoolteachers, firefighters and other ordinary citizens who play by the rules are forced to pick up the slack.

    Over the past four years, we have significantly increased our resources and focus on offshore tax evasion, and the results have been substantial. We upped the ante in a meaningful way with our work on Swiss financial institutions – where for the first time in history, a bank secrecy jurisdiction turned over thousands of names and account numbers.

    As we increased our enforcement efforts and gained significant momentum, we gave taxpayers a chance to come in voluntarily and avoid going to jail. In a typical year, we used to get 100 or so taxpayers who used our voluntary disclosure program. For this program, we thought that figure would rise to maybe 1,000.

    So, we are very pleased that through the end of 2011, we’ve had approximately 33,000 voluntary disclosures from individuals who came in under several special programs we started in 2009. To date, these individuals have paid back taxes and stiff penalties amounting to more than $4.4 billion, and the number continues to grow. We are now mining the information we have received to date and have launched our next wave of investigations on banks, bankers, intermediaries and taxpayers.

    Collecting additional revenue for past misdeeds – as important as that may be – is not the only consideration here. It is perhaps more important that we’re bringing U.S. taxpayers back into the system…back into compliance… so they properly report and pay their taxes for years to come. We have fundamentally changed the risk calculus of taxpayers who are thinking about hiding their money overseas, and we are well on our way to deterring the next generation of taxpayers from using hidden bank accounts to cheat on their taxes.”

    Notice that the focus is on penalties and enforcement. “Bringing U.S. taxpayers back into compliance” is given an honorable mention.

    This is not the first time he has said this. Here is a speech from May 2010 at John Hopkins:

    “Let me begin with our efforts to combat offshore tax evasion.

    During my tenure as Commissioner, I’ve made putting a significant dent in offshore tax evasion a major priority. In the U.S. and other nations, we view offshore tax evasion as an issue of fundamental fairness. Wealthy people who unlawfully hide their money offshore aren’t paying the taxes they owe, while schoolteachers, firefighters and other ordinary citizens who play by the rules are forced to pick up the slack.

    Our approach follows a natural course…cleaning up the abuses of the past and then mining and leveraging the data we receive to mount a greater attack on the abuse. A good example is our work on the Swiss bank – UBS – where for the first time in history, a bank secrecy jurisdiction turned over thousands of names and account numbers.

    As we increased our enforcement efforts and gained significant momentum, we gave taxpayers their best chance to come in voluntarily and avoid going to jail. Now, in a typical year, we get 100 or so taxpayers who use our voluntary disclosure program. For this program, we thought that figure would rise to maybe 1,000.

    So, we were very pleased that we had approximately 15,000 voluntary disclosures from individuals who came in under a special program we created, which entailed payment of back taxes and stiff penalties. And since it closed, we’ve received an additional 4,000 voluntary disclosures from individuals with secret bank accounts from around the world. We’ve even launched a second disclosure program with much tougher financial penalties – but no jail time – if taxpayers come clean with us. We are now mining the information we have received to date and have launched our next wave of investigations on banks, bankers, intermediaries and taxpayers.

    Collecting additional revenue for past misdeeds – as important as that may be – is not the main consideration here. It’s equally important that we’re bringing U.S. taxpayers back into the system…back into compliance… so they properly report and pay their taxes for years to come.”

    Again the focus in on penalties and not bringing taxpayers back into the system.

    Many people are of the view that Mr. Shulman’s OVDI programs have made people more reluctant to come back into the system. It’s too bad. Greater rates of compliance would be good for everybody. Greater rates of compliance would be an investment in the future of the U.S. economy. But, it looks as though Mr. Shulman is not primarily interested in investment.

    It’s all about forms and penalties!

  36. An interesting (sad) read
    “Re: American marrying Swiss tax confusion!
    In addition to issues surrounding tax liability, there are also reporting requirements to consider.

    Both of you should read up on the reporting requirements – then decide together how you will handle financial matters. Or better yet, see a tax professional – together.

    (I know of two FBAR divorces – a very sad state of affairs.)

    And another thing to discuss: Uncle Sam’s sledgehammer is going to hit your future children, even if they never set foot on US soil – so you need to consider that too when making family financial arrangements.

  37. @recalcitrantexpat
    April 8, 2012 at 9:12 pm
    ” @badger- I hope that you aren’t trying to make an argument for better service because that is not what expats want…..”

    I was actually just trying to underscore the continued illogic and inconsistency that the US and IRS show by the way their words and actions are consistently at odds. In other words the ‘bad faith’ that Shulman consistently shows along with what can only be a deliberate and persistent (or ‘evasive’?) strategy whenever he speaks about the nature of the IRS, ‘enforcement’ and his priorities. He stays on his message, and never ever touches on the issues of taxpayers outside the US except in his deliberate and disingenuous cloak and mantle of ‘evasion’-speak. He pretends in that video that he and the IRS are really just a friendly helpful agency who want to assist ‘taxpayers’. He does not ask for money to help expats – only for enforcement. He does not want to assist; he wants to generate penalties in lieu of the taxes that don’t actually exist. His refusal to answer the TAS, and refusal to release an analysis of the penalties vs. taxes collected in the OVD programs are evidence of ‘willful’ ‘evasion’ and deliberate ‘non-disclosure’.

    I think this is illustrated aptly by the excerpts from his other speeches – above – (thanks @renounceuscitizenship).

    Better service would not address the insanity of the system as applied to those outside the US, those with dual citizenship, and those inside the US with legitimate assets in their home countries. Better service would not stop the IRS from overreach, or Congress from enacting punitive and stupid laws to impose on others without consent or meaningful representation. It would not address any of the injustices we are trying to flag, or the FBAR and FATCA madness and unethical penalties, and privacy infringements on the accounts of non-US individuals in other countries. This isn’t even about actual ‘tax’ – much as he likes to repeat that. It is about the system itself and how it is grinding up anyone it comes across.

    As per the cost of sending out agents periodically to embassies and consulates in Canada. They cancelled those sessions due to budget cuts – that is noted on the embassy sites. I wouldn’t have expected that they would keep fulltime IRS staff there – although some of the sites in Europe seem to have permanent staff available to the public via parttime hours. My point was that I don’t see that it would cost much to routinely have sessions over period of days, every year, just across the border in two of the largest cities in Canada – with large expat populations – and they can do this now virtually via webinars, etc. I just noted that it was another egregious case where they actively choose not to provide what they say they believe in – in spite of what Shulman says in all his speeches. There is no will to do it, because that is not their actual aim or priority. They say they want ‘compliance’, but do nothing constructive towards that. Therefore it is heavily fined non-compliance that is actually their goal.

  38. Mr. Douglas Shulman is 100% responsible for the administration of OVDI. He made a deliberate and conscious choice to treat minnows no differently than whales. He has been pretending that he don’t understand the difference between minnows and whales. You can’t teach difference to people who pretend to not understand. So he will get whatever punishment God gives him in hell, since he can’t pretend before the God. He can’t ignore God’s TAD or request for information, as he has been deliberately doing with Nina Olson or refusing to divulge information requested by ACA under FOIA. He may not be corrupt, but an overzealous bureaucrat going out of his way to satisfy his ego and self-importance, even if it causes irreparable damage to the US economy and life’s of expats living abroad for decades.

    The US ambassador to Canada Mr. Jacobson said: We are not unreasonable. We are not unsympathetic. We are not irresponsible. This clearly shows, Mr. Schulman behavior is irresponsible and unreasonable.

    We can’t blame Shulman for citizen based taxation, but he is certainly 100% responsible for the treatment of each and every minnow entered OVDI in good faith. He is certainly responsible for not yet publishing alternative disclosure path for minnow, which was promised many times. How complicated it is to say, file past 6 years taxes and pay interest, if any tax is due. No FBAR penalties on all the accounts in are in expat’s country of residency (if it is not a tax heaven), if minnow have been living abroad for all 6 years and hiding no money in financial accounts in tax heaven to evade US taxes.

    Mr. Shulman using OVDI as a trap to punish defenseless minnows, since IRM clearly asks for a warning letter, if the violation is non-willful, while he is helpless in case of most of the whales, who can afford high priced lawyers. The minnows in OVDI are punished for their ignorance and naively trying to do right thing, as soon as they were aware of their obligations. Collecting penalties from minnows is easy, since they are exposed themselves by entering OVDI and can’t defend themselves living thousands of miles from a US-lawyer or even aware of US legal framework.

  39. @desi,
    an interesting and very sad twist – re the FBAR marriage jitters, and the FBAR divorces. I know of two with extremely strained relationships and stress for the whole family – as a direct result of OVDI and FBARs. The TAS should be told about the engagement example – it is insane to have a tax system and expatriate laws determining how we marry, causing divorces, the breakup of families, depression, etc. Will we now establish FBAR and FATCA pre-marital and divorce counselling sessions with tax attorneys and CPAs? And deciding how to prevent our children and grandchildren from inheriting the burden – like genetic counselling – but for US citizenship? I saw that the site goes on to discuss children too. So US tax planning has to start pre-birth.

  40. @ All

    I just want to make clear that I am by no means suggesting that Shulman be “let off the hook.” Renounce asked for some background on the man and since he’s from my neck of the woods, I can imagine what his simple “core” is like. Then OMG gave the example of a corrupt Manager who had committed massive theft and was let go quietly so as not to damage the company’s reputation. My comment about Shulman knowing what “right” was, was in context to the mention of theft. As far as damaging the reputation of the IRS, well, according to Shulman, IRS is doing way better on the American Customer Satisfaction Index; in 1998, an all time low rating of 32% and 2011, up to an all time high rating of 73%. Obviously, they didn’t ask any expats.

    I recognize Badger’s point that Shulman never mentions expats abroad and tax havens and that this is a deliberate and conscious strategy. I wonder if anyone has ever asked him about the difference of effect of OVDI on expats abroad and resident USC’s. By constantly using that strategy, he reinforces the omission and probably nobody stateside would even think of it. After the speech at the National Press Club, I expected the Q&A session would involve people in the audience but all the questions were read by the woman who emceed the program. Probably he knew in advance what he would be asked.

    I don’t have a lot of faith or hope that this situation will be rectified and agree, the only real power lies in renouncing. Anything else means you have to be violated, over and over again.

  41. Sad part is OVDI caused expats and dual-citizens to plead guilty to a crime they didn’t commit. The IRS committed at the time of amending FBAR law in 2003 to educate tax payers and the law provided safety net of reasonable cause and non-willful violation, when there is no tax liability. The IRS treating all failures as willful criminal tax evasion is violation of the law and congressional intention.

    If expat owe no taxes, why would he intentionally break FBAR law indented for terrorists and money launderers, which can ruin his life? This is putting lot of emotional stress on law abiding expats and causing crippling distraction from one’s jobs and businesses. Only good thing is I last 6 pounds due to the stress, which I couldn’t do in previous 3 years.

  42. To borrow a much loved expression used by many US Homelanders, “Don’t let the door hit you on the way out, Shulman!”

  43. Mr. Douglas Shulman nomination was confirmed by the full U.S. Senate on March 14, 2008 and he was sworn in on March 24, 2008. Why is he leaving early? May be he is being pushed out. Obama may have asked him to leave early to nominate next commissioner, just in case Obama losses elections. Obama may be not happy with his performance, or inability to comprehend even simple things like difference between minnows and whales, or difference between collecting taxes and penalties. I hope next commissioner is more intelligent to know the difference and have respect for laws (e.g. deal with FOIA and TAD as required by law).

  44. @ expat_business_man If Obama wants Shulman out it’s because Obama wishes to make tax policy more radical (i.e., in the marxist direction), not because he was displeased that Shulman couldn’t distinguish between minnows and whales. I plead with you folks: Obama IS the problem. This stuff is happening because Obama promised hope and change: Hope for folks on welfare who voted for him and change to the taxing schemes of those who don’t vote for him (the wealthy and expats). Obama is a redistributionist. He wants to redistribute your money that you earned internationally and give it to the people who put him in power. The person who Obama replaces Shulman with will only make it worse. Much worse. Believe me.

  45. I agree with Petros. Obama is the real problem. We didn’t know him before he got elected but we know him now. If he wins reelection God help America because they’ll need it.

  46. @Petros, Allow me to make one important clarification: I think you will find that the Expat community voted heavily in favor of Obama because during his campaign he comitted to “level the playling field” for US citizens living abroad. He was very clear in this. But once elected he promptly did nothing to keep this vote-getting commitment. ACA leadership has made many attempts to follow him up on this commitment, but the response has been absolutey zero. It is if this commitment had never been made. His actions speak much louder than his words. I suspect and sincerely hope that in this next election the vote will be very lopsided against him. To those of you who are expats, please keep this in mind.

  47. @all, Well I sincerely hope he is not re-elected, BUT from what I am hearing from my family and friends, and their co-workers, they all feel he is going to be re-elected.. ARE THEY STUPID OR WHAT!! They complain about how he has run the country and then they talk about re-electing him.. I don’t get it..Please this can’t happen!!

  48. This is going to be a very important election. It will change the course of the United States for a long time. I sure hope he doesn’t get reelected because he is clueless about business.

    I was worried that Romney didn’t have what it took to beat Obama but after seeing what he did to Newt through negative ads I hope that he can do the same to Obama.

    The American people can’t possibly want 4 more years of this. If losing your job and home doesn’t make you want new leadership nothing will.

  49. @OMG, You are 100% right, surely to God they will not vote for him again. It will such a big mistake!!

  50. If Obama is a Marxist then Romney is Che Guevara! Give this theme a rest, While the ones introducing the legislation that concerns us are democrats the most vicious attacks on expatriates have traditionally come from Southern Republicans.

  51. Why do IRS Commissioners have 5 year terms instead of 4?

    What would cause a commissioner to leave almost 6 months before his term is up?

    First there were the 30 tax prosecutors that got transferred with no replacements and now Shulman is leaving early. Something is up.

  52. @Petros, I agree the Obama nominee would be more radical. But I hope he has respect for the laws.

    I was a democrat and last time I strongly supported Obama. Now I sincerely hope Obama is not re-elected. Last time millions of salient majority voted for him with false hopes and all of them now deeply disappointed. It won’t show up in monthly polls, but I believe the salient majority would abandon him. He made so many promises and change (created huge expectations), but not kept most of them and thoroughly disappointed the salient majority. There is no enthusiasm that existed in 2008.

    Now country is direction less. The US built and prospered on capitalism. Now Obama is pushing towards welfare or socialistic state that is against its core nature, which always end up in disaster. Different parts of a complex system drag various parts of the nation in different direction, making it direction less leading to disaster. If he re-elects it is disaster for the US, since he can push his agenda without fear of elections and will be aggressive attacks on congress that polarizes and divides the nation.

  53. Roger wrote

    @Petros, Allow me to make one important clarification: I think you will find that the Expat community voted heavily in favor of Obama …

    Roger, my line was incorrect. It is not that expats didn’t vote for Obama, it’s that their votes count for naught in the grand scheme of things, so that Obama et al. can safely ignore their issues.

  54. Joe wrote, “If Obama is a Marxist then Romney is Che Guevara!”

    Oh sorry. Obama is not a “marxist”, he’s a redistributionist.

    A rose by any other name …

  55. @petros, Expats votes count for very little, but remember that it was the 2000 election that was won by one electorial vote over Gore. That was because when the votes were counted, and recounted under close scrutiny of the the Florida courts, Bush won Florida by 327 votes. It was the overseas absentee ballots that gave him rhe slim majority that decided the national election. The Miami Herald, which had supported Gore and was in the forefront in demanding a recount, conducted its own post-mortem investigation and concluded that Bush had indeed won the election.

    One of the rare cases where the overseas American votes did in fact count.

  56. @omg
    ‘What would cause a commissioner to leave almost 6 months before his term is up?’ I think you might be reading too much into his leaving. There could be 101 reasons that he is leaving. I don’t believe it is indicative of somethng being up.Over the years, you see this sort of thing occur many, many times. Perhaps he has a job offer that he just can’t refuse!

    I am just grateful that as someone who has not considered myself an American for 40+ years, that I don’t have to vote and won’t be voting. I agree that Obama is a disaster but I haven’t seen anyone on the Republican side that I would trust either. With possibly one exception – Ron Paul – and he is such a long shot that ‘it ain’t gonna happen’.

  57. I hate to say it, but I believe Obama’s chances of reelection are very good. The more and more the election becomes about “class warfare”, the better his chances are. Petros is right in that Obama is about the redistribution of wealth. In December he launched his campaign in Kansas with the theme of class warfare. In January of 2012 his State of the Union Address emphasized ‘class warfare”.

    Democracy in America has become a game where the political process is used to get somebody else to pay your bills. So, far 1/3 (or more) of U.S. taxpayers don’t pay taxes (relying on the revenues generated from the rest).

    He realizes that a majority of American voters would prefer to have the minority pay their bills. At every campaign stop the message will be:

    Vote for Obama – I will make sure that somebody else pays your bills!

    Great speech in Kansas:

  58. @ex_pat_businessman; re”Only good thing is I last 6 pounds due to the stress, which I couldn’t do in previous 3 years.”
    Me too. What shall we call the new diet?

  59. @renounceuscitizenship, how about this for a slogan:

    Vote for Obama and you may never have to pay taxes again since it will be impossible to find a job due to his job killing policies.

  60. @Badger: You said: What shall we call the new diet?

    How about: Shulman ‘bait-and-switch” FBAR weight loss plan?

  61. It is unproductive to argue whether the Dems or Republicans are worse. We cannot influence the election. This discussion draws attention from our real problems- how to deal with the US government. T o think it would be better under the GOP is quite unrealistic.

  62. @Chester12

    The question is whether we would be better able to deal with the U.S. government under Romney or under Obama.

    What we know is that there is no way to deal with an Obama government. A Romney government might be different.

  63. @omghesstillanamerican- I am not a lover of President Obama but in fairness to him I would point out that the rise in America’s unemployment began in 2007 under Bush. I would also point out that it was Bush who used trumped up charges and invaded a sovereign nation that was not at war with the U.S. He then proceeded to invade another nation and in the process none of these wars was funded. It was also Bush who brought in the tax cuts for the wealthy and implemented a drug program for seniors, none of which was paid for.
    I have watched the critics slam the recovery as being one of the worst recoveries ever but they refuse to admit that this recession was one of the worst ever. America has suffered a very traumatic blow to its financial under pinnings and this won’t be fixed quickly. Some of it will never be reparied. The U.S. economy may forever bear a scar from the 2008 collaspe.
    Neither the Republicans nor the Democrats are friends of the U.S. expat. Both parties believe in American Exceptionalism and citizen taxation is a part of this shared mythos. Attacking expats is a cheap, pain free, no risk way to gain votes at home. Expats have no control over the image of them that is presented by polticians to resident Americans and resident Americans could care less about the lives of expats. Unless the expat community wants to start buying advertising time on t.v. and radio the true story about them will never get out.

  64. I have to disagree Chester12. The Republicans have been pushing for a territorial tax system for awhile now. That’s the beginning to the solution to our problem. It may start with corporations but logically it has to quickly lead to residence based taxation for individuals too. Since corporations and individuals are both labeled “US Persons” by the IRS eventually they deserve equal treatment.

    Obama on the other hand has pushed back hard whenever the Republicans put forward a territorial tax plan.

    We are caught in the middle of an ideological war. The true story is not being told by any newspapers. This war will be won by those with the most money, which in this case are corporations. That can only mean good news for us too eventually.

  65. @omghesstillanamerican

    Well put – I agree that this is the link. Both corporations and people are U.S. persons. Hence, the pressure to treat them in the same way. It is very very likely that the U.S. will move to territorial taxation for its corporations.

    This is also a way to argue the issue where the focus will NOT be on wealthy expats on the beach (a person I have never met but is ingrained in the American psyche).

  66. @recalcitrantexpat

    ‘Both parties believe in American Exceptionalism’ – How true. In fact, I think that probably all American homelanders have that same narcissistic view. The attitude is they are ‘the best’ and therefore, their way is the only ‘right’ way.

  67. I’m seeing all of this from the eyes of a lowly Canadian beaver. To me it always looks like the American Eagle is trying to fly with two right wings. It’s only an intransigent belief in American “exceptionalism” which tricks it into thinking it is soaring when in essence it is flapping on the ground like every other creature country in the world today. It matters not which party is in power. Both are dedicated to making the rich richer and the poor poorer and too bad for the middle class because they are being forced down not up. Sadly back in Canada, Harper adores the American Eagle so much he eagerly feeds it our sovereignty just to ingratiate himself to it.

  68. Chester12 has it right. To pin any hope to donkey or elephant is delusional. It is all a tale of a beast. The system will grind along regardless of puppets and spectacle. Any anticipation of direction reversal runs counter to the long view. A power in decline is a power in denial, and therefore even less likely to do an about face. Each Brocker has exactly one real vote — to that vote, in most cases, ten toes are attached.

  69. Ok all…. I have resisted being drawn into the partisan arguments about which party is most likely move us towards a ‘territorial tax system’ for individuals. I am not taking a partisan side. I would say, sadly, neither.

    I hear the arguments that the Republicans want a “territorial” system for Corporations, and so it would naturally follow that it would also include mere mortal individuals.

    My answer to that is simply this.

    If that were true, than individuals should be able to keep their passive interest earnings or “profits” untaxed until they are repatriated back to the US just like Corporations currently do and have done for a long time under Republican Administrations as well as Democratic ones. Why didn’t that get extended to “mere mortals” as a natural trickle down?

    The answer,… mere mortals did not have the lobby money to buy that loophole for themselves.

    Bottomline, Money drives all tax legislation, and if you think they will extend a benefit that Corporations get by “buying their rates”, as a compassionate releif to us little persons, I think you are dreaming. I know you want to “hope” it is so, but I have seen no evidence that this has been the case in the past.

    Maybe the Republicans will now somehow be “really different” than they have been in the past. But, when or if they come to power again, nothing I have seen gives me any comfort this is so. I fear more foreign wars of intervention, as the only Republican talking sense in that arena, Ron Paul, is laughed down in the debates while each other Republican tries to out do the other as the most belligerent about what they will do again Iran, North Korea, Afganistan, or you name the country.

    Of course Obama has mostly followed Bush Administration policies when it comes to extending the “good” war in Afghanistan, and the pull out of Iraq was just following the Republican time table, so nothing to be claimed there.

    We certainly have evidence that Republicans too know how to deficit spend, grow a government’s size and reach, add to tax complexity, pass unfunded mandates and launch wars on a credit card.

    I am not saying I am lining up in support of the Dems, I am just discouraged that either of the two parties will make any difference at all when it comes to territorial tax system.

    If some of you have not yet listened to the “This American Life” story on “Take the Money and Run for Office”, I would encourage you to do so. Money is the ruling power in Congress now, and Expats have no organized Money Lobby to sway things for us. I doubt the Corporations care one whit about whether or not a Territorial system is extended to individuals also. They aren’t going to waste one cent of their lobby efforts on Congressman saying, “Oh please also include individuals in this.”

    I hate to be so cynical these days, but it is what it is.

    Right now nothing is in the works to change the Money system, so party badge means nothing when it comes to ruling America. Money is everything. Lets face it, there is one party in America these days, the Corporate Party and the Dems and Rep battles are just an entertaining sideshow. Nothing about the current crop of Republicans leads me to believe there will be any fundamental changes to the role of Money in the political system should one of them come to power. And Obama has also started his SuperPac in the money arms race for office.

  70. @Just me,

    Thanks for your words of wisdom. I always look forward to reading your entries.

    Cheers mate!

  71. Thanks again, Just Me. Your wise words are a sobering reminder that the issues we face are far greater than traditional party politics will ever solve. Unfortunately, the same thing can be said for virtually all the issues that the U.S. faces today. The two-party system, the U.S. Constitution, the Bill of Rights and American democracy itself have become quaint anachronisms. The realpolitik of American life is indeed now dictated entirely by its oligarchy. The American Dream has finally reached its logical conclusion: the forfeiture of every single aspect of life to the blind, all-consuming imperative of money and profit.

  72. so can the minnows join and become a superpac. If there are
    45 million immigrants and expats and even if 30% want to join that is close to 13 million. each donates $20-30 bucks and we have a super pac with about 200-300 million funding. dont we? how do we mobilize?

  73. @ desi

    Think that will be enough to counter Mitt (poster-boy for real offshore tax-havens) Romney’s SuperPac?

  74. @Expat4ever
    I would be more readable if I learned how to spell relief, as in “compassionate relief to us little persons”. duh

    Thanks for the Southern Cross tune. Can see it ever night from the deck. I live in the country so the stars shine brightly and remind me how insignificant all of these travails are, and not too be too soapy, as does this Carl Sagan video. Shulman kinda recedes into insignificance when viewed against this background.

    Anyway, that is how I keep my sanity when dealing with what dysfunctional governments and its bureaucrats throw at me. 🙂

  75. @Just Me — the nature of my anti-Obama comments are not intended to be partisan, as I am a supporter of neither party, Republican or Democrat, which are only relevant in terms of how their policies affect everyone in the world. But I will never be voting in another US election because I am no longer a US citizen.

    In any case, thanks for your extended comment. I agree with the pessimism. I do think that Ron Paul is the only one making sense. I have only the view that Romney may be less evil to expats than Obama has already proven himself to be; but of course, such a theory remains untested.

  76. @Petros

    I take your point especially after reading Obama’s promises to Americans Abroad. He certainly has forgotten them. I will keep that in mind if a Republican makes similar promises. However, I doubt we will hear any, as generally speaking Reps are more vested in the Exceptionalism myth, and therefore think the U.S. citizenship/passport is so exceptionally valuable that it can (it must) be taxed around the world. The cost of ownership is worth it!! That idea is being put to the test north of the border, and being shown NOT to be true at some level, but probably not enough to register in the feeble myopic “real American” mind which closely identifies with Republicans.

  77. Pingback: My response on Jack Townsend’s Open Forum Comments to Congress and IRS Regarding Tax Administration for Offshore Accounts (4/9/12) | The Isaac Brock Society

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