Asher Rubinstein, a highly experienced American tax lawyer, has written a most interesting article on his website about the latest developments linked to the voluntary disclosure programs of the IRS and the related penalties that the IRS has imposed linked to non-filing of the FBAR.
Use this link to go to the article, "Standing up to IRS 'Bait and Switch' Tactics" written on July 22, 2011. Be sure to also click on the link “my article” within “Standing up,” which leads you to a prior article dated June 20, 2011 entitled "Offshore Voluntary Disclosure Penalties: The IRS Quietly Drops a Bombshell". The two articles provide complete understanding. ACA is grateful that experienced lawyers are taking a public stand on what apparently has been serious abuse by the IRS and thanks Mr. Rubinstein for permission to link to his articles. ACA reminds its readers that they can submit their own testimony on such issues here.