Are you a Superminnow?

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Has it been awhile since you've dropped your Uncle Sugar a postcard from Buenos Aires?  Or were you under the impression that the IRS had simply dropped you from their mailing list out of disinterest?  Long time, no file?

Well, cheer-up expat tax slackers!  This month, the IRS has announced the details of a special program just for you ...but only if you are a superminnow.

Streamlined, that's what it is!  Specifically, it's the New Streamlined Filing Compliance Procedures for Non-Resident, Non-Filer U.S. Taxpayers.  To see if you qualify, you'll need to answer a questionaire all designed with you in mind.

In the main, the program is directed toward U.S.-type folks who have lived outside das homeland since at least 2008, have not filed a tax return during that time, and don´t owe more than $1500 dollars in tax for any of the tax years 2009 through 2012 ...superminnows rather than Big Fish.

Generally, if you can´t answer yes to all of the above, you ain´t bona fide and cain't be streamlined.  On the other hand, if that describes you to a T, you may yet acheive superminnow status.

The next section of the questionaire concerns itself (and you) with foreign bank accounts and retirement accounts and whether you knew that you had to report that stuff to the IRS.  Then it goes into questions about how fancy your tax advice has been lo these many years and if you have been reporting your income to your country of residence.  If it looks like you've been hiding cash from the taxman when you knew it was wrong, you can forget about becoming a superminnow.

If, however, you can swear that:

• none of the returns submitted through this program claim a refund;
• there is no material economic activity in the United States;
• you have declared all of his/her income in your country of residence;
• you are not under audit or investigation by the IRS;
• you have never gotten into FBAR trouble before ...not even a warning;
• you have no financial interest or authority over a financial account(s) outside Argentina;
• you have no financial interest in an entity or entities outside Argentina;
• you have no U.S. source income;
• or that you don´t use sophisticated tax planning or avoidance...

you might be able to get right with your Uncle, pay your back tax (if any), and avoid an audit and penalties.

Swim away, little fishy!  Swim away.