right, my case is different from US expats living in Canada. as I have said "it is not fair for US expats to face FBAR penalty even if they owe US tax for whatever reason" -- because offshore should be related to the person where he/she lives
it seems IRS wants to get US expats into FBAR/tax comliance as well -- but with less penalty of 5%.
As long as the law is in place, i think people really do not have choice for sure if the gov will use the law or not -- so for the sake of certainty and peace in mind, to get into OVDI seems a good choice (if there is a tax issue).
if not, i would just go quiet disclosure..
Dual-since-childhood
Moderator: Mark T Serbinski CA CPA