Michael Lewis at the Toronto Star covers the Saverin story and quotes me from an Isaac Brock Society comment.
Lewis also cites Nina Olson (emphasis mine),
U.S. National Taxpayer watchdog Nina Olson in a public letter warned that the IRS is driving “benign actors” underground with draconian penalties and a byzantine international tax reporting regime.
I googled this term, “benign actors” and found the March 5 letter from ACA to Douglas Shulman, Commissioner of the IRS:
In one of Ms. Olson’s communications to you, she explained that the OVDP “attracted both bad actors and benign actors who made honest mistakes. If the IRS had clearly communicated that everyone would be presumed to be a bad actor (or willful violator) as the TAD appeal asserts, it would not have attracted benign actors.” In other words, the OVDP program has treated everyone who entered it as a tax cheat, actively hiding funds overseas, whereas many who came into the program were Americans living overseas who had no idea they had to make a tax declaration to the United States. By doing so, the IRS has adopted a camouflaged policy of taxing assets of Americans abroad through penalties, when in fact the United States officially taxes only income and capital gains.
Lewis, however, writes the anonymous IRS response to Nina Olsen:
The IRS in response said “measures are in place to prevent taxpayers from being subjected to financially devastating penalties.”
Really? Is that why some of us can’t sleep at night? The IRS threats to devastate the wealth of US citizens outside the USA remain.