re: 77,000 different foreign banks in 70 countries reporting to IRS now

Understood.

And no hard feelings to NCtigah. I retract my attacks. Maybe we'll try and discuss at a later time. I need to sign off tonight.

You are...of course...correct. But his gotcha is the "savings" account argument.

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I understand nc. This guy is an accountant that specializes in international transactions.

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I know. Hence . . .

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you'd claim this is in your wheelhouse

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He seems to accounting here, what TUba is to Physics.

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The vast majority of fatca disclosures have more than just savings accounts reported

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It would be hard to seriously imagine a tax avoidance strategy involving large assets sitting in a bank's savings account. That was the point. Hard to imagine it even in higher interest locales like Pakistan or Brazil. Much less in the sub1%ROI range most 1st world accounts would render.

Risk/return compared with Tax Free Munis 5yr annualized running at ~6.5% would be nuts. Given other tax avoidance options, it's hard to believe ANYone with ability to accrue substantial assets would be stupid enough to drop them in a Cyprus-type Bank Savings Account for sole purpose of US tax avoidance. In terms of invitation for disaster, IRS discovery would rank way down the list.

Now accounts for money laundering, dummy corporations, pass-thru investment entities, etc. are obviously a different deal.

What I'd like to know is the number of Americans with foreign bank accounts vs the number suspected of fraud. I'd bet both are low with the fraud ratio being substantially off the "1" figure the OP (or TnM's "exponentially" comment) would imply.

My cynical side sees this forwarded as little more than a salacious attention distracting story designed to get folks like the OP excitedly rubbing their hands together, anticipating another strike at American affluence. The story comes in advance of Select Committee Hearings, along with an anticipated IRS-unfriendly November election result. Strip away the shiny paint, and there's no there there.

As an aside, it seems any financial institution marketing itself to the taxhaven crowd would simply fractionate larger accounts to sub$50K size, and dodge reporting.

I'll try and respond to some of this when I have a chance.

For now, I'll just say NC is way way off in his thinking and doesn't understand much of anything going on in this area.

And bonds is out of his element on this subject.

And not sure what outrank me means, but bonds, I assure you you don't.

It means as an accountant, You are by definition a bean counter. You crunch numbers. Which is important. But legal strategy planing strategy and overall tax strategy is left to lawyers. The use of foreign benefits can be a very effective planning tool. You Stick to crunching the numbers. You aren't qualified for the planning side.

Here is the little bit I understand, I work and have a resident visa in a foriegn country. The laws here require that I am paid in country and now no bank wants to deal with me for what is basically a clearing account. My income is already reported to the IRS by my employer. No bank wants to deal with this over the miniscule profits to be made off expats accounts.Our idiotic IRS is creating problems just because they can and do not care who they screw. Now you two carry on with your pissing contest

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It means as an accountant, You are by definition a bean counter. You crunch numbers. Which is important. But legal strategy planing strategy and overall tax strategy is left to lawyers. The use of foreign benefits can be a very effective planning tool. You Stick to crunching the numbers. You aren't qualified for the planning side.

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I work for a law firm dummy. You have no idea what I do. Number crunching ain't it. I highly doubt you could hold my jock when it comes to international planning and structuring TBH.

If you aren't an attorney you aren't prepared an shouldn't be doing planning. Be an accountant. That is what you are trained for If you want to plan go to law school then get your LLM. If an accountant is doing any planning hopefully it's not for anyone with substantial assets. That would be dangerous. I would imagine the lawyers at your job do the heavy lifting.

Yikes. An accountant is supposed to perform accounting fictions and file returns. I hope someone who is qualified reviews your "planning" before anything is implemented. That is malpractice waiting to happen.