Mr. FBAR And The Future Of US Citizenship Abroad - Greg Smith Reflects On 25 Years Of Living Overseas

March 11, 2023 - Participants include:

 

Gregory Smith - @BlogNDog

 

John Richardson - @Expatriationlaw

 

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Greg Smith has lived outside the United States for most of his life. He has lived in six U.S. states and 19 different countries. He is presently in Prague where (along with other things) he runs a Hostel for visitors to Prague.

He was previously on the ACA Board.

In this podcast, Greg a wide range of thoughts and perceptions about his 25+ years of living under the tyranny of Mr. FBAR and the U.S. extra-territorial tax, reporting and penalty regime.

 

This podcast was arranged because of the following Twitter exchange on March 11/23 about the Bittner case:

 

@Expatriationlaw

The real story is that this #FBAR issue even had to be resolved by the Supreme Court. Think of it: The IRS is levying life altering penalties based on violations of a statute that is so unclear that even the Supreme Court couldn’t agree on what was intended! “The American Way”

 

@BlogNDog replies with:

 

This has long been my take on this issue - what is it that makes the IRS feel compelled to fight all the way to the Supreme Court in pursuit of the most extreme possible interpretation of the law? There may be some ambiguity about what the laws says, but there is no question>>

 

>>that the IRS has the discretionary authority to not impose the highest penalty available. Let the question about whether they *could* impose a higher penalty if they chose to remain unanswered

 

The full discussion is on Twitter at:

 

https://twitter.com/ExpatriationLaw/status/1634539926036332547