*mouses over link*

Hey Subby, I see what you did there at the end

Currently being audited

/no kicks being had

/Hot like a fistfulla cash

Most of these people are multi-millionaires or billionaires who would have continued to evade taxes were it not for the Swiss banks showing the IRS the books. I doubt they'll be much sympathy for them. Nevertheless, if the IRS makes the deal, they have to stick by the terms. The real beneficiaries will be the attorneys and CPAs who get to bill additional hours as a result of the mistakes.

I have no problem with the IRS going to these peoples homes and ass raping them.

Satanic_Hamster: I have no problem with the IRS going to these peoples homes and ass raping them.

Seems to me you have an unhealthy interest in ass rape. Is there anything you'd care to admit?

But now those $Billions sitting untouched in off-shore accounts can't make JOBS here in the US!

Won't they think of the JOBS?

Atomic Spunk: Satanic_Hamster: I have no problem with the IRS going to these peoples homes and ass raping them.

Seems to me you have an unhealthy interest in ass rape. Is there anything you'd care to admit?

Oh, so it's ok to like rape but not to have a particular form of rape you like?

Rich people problems

rev. dave: Rich people problems

I hope they never find the $50 I have stashed in Tijuana Savings & Loan!

The 'interpretation' of FAQ 35 mentioned in the article is laughable. The actual quote:

Q34. If, after making a voluntary disclosure, a taxpayer disagrees with the 20 percent offshore penalty, what can the taxpayer do?

A34. If any part of the penalty structure is unacceptable to a taxpayer, that case will follow the standard audit process. All relevant years and issues will be subject to a complete examination. At the conclusion of the examination, all applicable penalties (including information return and FBAR penalties) will be imposed. Those penalties could be substantially greater than the 20 percent penalty. If the case is unagreed, the taxpayer will have recourse to Appeals.

Q35. Will examiners have any discretion to settle cases? For example, if a penalty for failing to file a Form 5471 for 6 years is $10,000 per year, will that be compared to 20 percent of the corporation's asset value? Would the lesser amount apply?

A35. Voluntary disclosure examiners do not have discretion to settle cases for amounts less than what is properly due and owing. These examiners will compare the 20 percent offshore penalty to the total penalties that would otherwise apply to a particular taxpayer. Under no circumstances will a taxpayer be required to pay a penalty greater than what he would otherwise be liable for under existing statutes. If the taxpayer disagrees with the IRS's determination, as set forth in the closing agreement, the taxpayer may request that the case be referred for a standard examination of all relevant years and issues. At the conclusion of this examination, all applicable penalties, including information return penalties and FBAR penalties, will be imposed. If, after the standard examination is concluded the case is closed unagreed, the taxpayer will have recourse to Appeals. See Q&A 34.

"We will not assess a penalty over the maximum allowed by law" is not anywhere near "We will assess the minimum penalty." Also note the included text of the answer to question 34, which is best translated as "If you want to argue about the deal, the deal is off."

People have been using these dodges to screw the rest of the American people for years. The IRS is an executive branch agency tasked to apply and administer the nation's tax laws fairly, which means they apply to everyone. Sympathy for people who believe they are not subject to the law is not high.