TAS stands for Taxpayer Advocate Service and they are the U.S. government agency with a mandate to keep an eye on the American "fisc."
The TAS is run by the NTA, the National Taxpayer Advocate, Nina Olson, who is, in the eyes of many Americans abroad, a queen among women, an ally, and our heroine. Why?
Because in her 2011 annual report to the US Congress released earlier this year Madame Olson singled out the IRS' treatment of U.S. persons abroad in the amnesty programs (aka OVDP - Offshore Voluntary Disclosure Programs) saying that the way the program was applied to certain categories of non-compliant taxpayers was positively draconian and may even have opened up the U.S. government to legal challenges.
Many of the people who went into these amnesty program were not criminals, they were simply folks who finally realized that they had a reporting obligation and wanted to make it right. For their willingness to come forward, they were "rewarded" with penalties (not necessarily back taxes mind you) that would have wiped them out financially. Some of these cases have been resolved and the fines and penalties lowered or forgiven entirely but I can assure you that trust for the IRS and the U.S. government right now is at an all time low. Another amnesty program has been announced by the IRS and I don't know of anyone who is even contemplating joining - they'd rather do a deep dive and never set foot in the U.S. again even if it means not being able to take care of elderly parents back home.
For all of the IRS chest beating over the "success" of these amnesty programs, the casualty has been trust and the willingness of non-compliant Americans abroad to come forward voluntarily. In fact I would even say that where many of the non-compliant middle-class American expatriates once felt that they had a moral obligation to set things right and file those damn forms, they now feel that they have a good moral case for NOT complying. This means that IRS will have to work harder and spend more taxpayer money bringing them (kicking and screaming all the way) back into the fold. As Madame Olson warned nearly a year ago in her report:
"The IRS’s miscommunication has consequences. If the government does not appear to treat benign actors fairly when they try to correct honest mistakes, then fewer people (even well-advised people) will try to correct their mistakes, and voluntary compliance will suffer. even if it were inclined to do so, the IRS does not have the resources to rely entirely on enforcement. the IRS needs taxpayers to cooperate and comply voluntarily. While an estimated five to seven million U.S. citizens reside abroad, the IRS received only 218,840 FBAR filings in 2008. By comparison, the government closed only 2,386 FBAR examinations and initiated only 21 criminal investigations in 2010.And now The Taxpayer Advocate Service and Nina Olson have come out with their 2013 objectives and how thrilled (and relieved) I was to see that Americans and Green Card holders abroad have not been forgotten. Click on the Areas of Focus link and scroll down to page 21 where they say:
While the ovdp attracted 15,364 applications (perhaps less than one percent of those who did not file FBARs), a more effective initiative would have prompted even more taxpayers to come into compliance without leaving those who did come forward feeling terrified, tricked, or cheated. By generating such ill will and mistrust, the IRS is squandering an opportunity to improve voluntary compliance. "
TAS Will Continue Advocating for American Taxpayers Abroad Who
Are Expressing Fear and Frustration about FBAR, FATCA and Other
Yes! And such efforts deserve positive reinforcement, don't you think? Madame Olson has a blog here where you can submit comments and I think a "thank you and please keep up the good work" for TAS' efforts would be a darn good idea. Clearly they have been listening and looking into it and they don't like what they see.
Those of us who are living this nightmare are screaming and kicking at the doors of our lawmakers trying to get some attention to how these issues impact the average mostly middle-class American citizen or Green Card holders abroad. For our trouble we are often dismissed out of hand because clearly there is no such thing as a middle-class American abroad, right? My answer to this one is simply to say if we actually had the kind of money we are accused of hiding then we'd be doing the American thing and buying ourselves a couple of politicians to vote on our behalf. Since that isn't happening and U.S. lawmakers hardly give us the time of day (much less respond to our mail) I think we can safely say that that those billions and billions of ill-gotten gains supposedly hidden in offshore bank accounts exist only in the minds of the American homelanders.
But we do have one ally within the U.S. government who is taking us seriously and both the TAS and the NTA have my eternal gratitude for their excellent work.