Non-resident Streamlined Tax Disclosure
The IRS came out, as promised, on 31 August 2012 with the details of their new streamlined disclosure program specifically for Americans residing abroad. The regulations can be found here as well as a questionnaire for applicants. While this new IRS program attempts to facilitate compliance for those who owe little or no US tax, but who have not previously filed, it carries multiple restrictions and possibly unpleasant consequences. ACA strongly advises any Americans abroad contemplating entering this program to consult a US tax lawyer fully knowledgeable in these issues as well as the recent history of the IRS voluntary disclosure programs. An article by Shamik Trivedi, Streamlined Procedures for Low-Risk FBAR Filers May Not Have Wide Application, which appeared in Tax Notes Today on September 4, 2012, highlights the restrictions, limitations and risks of the new IRS program. Another critical review of the new IRS streamlined procedure for Americans resident abroad was published in September 2012 by Moodys LLP, a Canadian tax advisory.