Wednesday, March 26, 2014

Scope and Limitations of this Blog: It Is a Tax Crimes Blog, not a Tax Crimes Policy Blog (3/26/14)

I responded earlier today to a reader who emailed me.  The underlying theme of the reader's email to me was to complain or at least comment that, in my blog, I do not give a balanced view of the fairness of the tax law and its administration and that I tend to advocate positions that favor the law as it is.  I thought I would offer readers my thinking on that general subject, because it affects what and how I present discussions on this blog.

I conceive my blog as a forum to discuss the law as it is, including how it develops.  It is not a tax policy blog addressing issues of what the law ought to be.  Hence, for example, I have not advocated for or against FATCA or for or against the U.S. taxation of worldwide income or for or against how the U.S. taxes expats.  I have not advocated for or against the IRS Offshore Voluntary Disclosure initiatives (OVDI/P), although I have occasionally said that there are features of those initiatives that, were I in charge (I am not), I would have implemented differently.  I try to offer readers discussion of the law to assist in understanding and navigating the law as it is.  (I have worded this to remind readers that I am not offering them tax advice on this blog; see the page on Lay Reader Limitations to the right, here.)

Readers wanting to post comments on tax policy issues -- even if just complaints as to what the law is now -- are welcome to do so.  I probably will not respond to those comments but other readers certainly can.  For example, those wanting to complain about the IRS OVDI/P may certainly do so.  I will not defend or attack OVDI/P.  I will, where appropriate, discuss features of OVDI/P that may be useful for readers in understanding those programs.

I want readers to understand that I have limited resources to commit to this blog.  I do basically all the work on the blog.  A number of readers and colleagues point me to possible content for the blog, but in terms of understanding issues and presenting them in a way that I hope is meaningful to readers, I do all that work.  I also practice law where I have to spend time serving clients.  I also have a family and other interests that occupy time.  Hence, I am limited in my resources that I can commit to the blog.  The reader who sent the email noted above said:  "How about using your significant resources to investigate (not quote somebody) on the true number of applications, both processed and pending, for certificates of loss of (US) nationality?"  As I read the comment,  he or she is really complaining that the law and  its implementation are driving U.S. citizens to abandon citizenship, as an argument that the law and its implementation are wrong and should be changed.  That's a tax policy issue.  That is not the focus of my blog.  I have limited resources to devote to matters within the intended scope of my blog and certainly do not have the resources imagined to go off on detours from the intended scope of my blog.

Given these limitations, the subjects I address on this blog are necessarily anecdotal -- the subjects that attract my interest.  There are tax crimes subjects involving the law as it is that do not draw my attention.  For example, return preparer tax fraud and stolen identity refund fraud are major tax crimes subjects.  Although I observe tax crimes initiatives in those areas, I just do not address them much in this blog.

With these limitations, I do hope this blog is useful to readers.  As I note in the general introduction to the blog at the top of the blog pages, the blog is really intended for tax professionals and tax students.  I know that, particularly in light of the IRS's offfshore account initiatives, the blog is now read by lay readers and, judging by the comments (all of which I do read), some of the lay readers have developed particular expertise in some facets of the law and tax administration relating to tax crimes.  Indeed, some of the lay readers may understand facets of the IRS's offshore account initiatives better than many tax professionals (including me).  I welcome their comments, whether as a comment on the blog or in an email to me.

Finally, I thank the readers of the blog for spending their limited resources reading my blog.  I would appreciate your comments as to how the blog may be improved.

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