“When Andrew Winfield applied to become a U.S. citizen in 2011, he realized he owed taxes on accounts he had left behind in his native England.  So he paid what he believed he owed — $2,800 in back taxes, plus the estimated interest and penalties – and entered the IRS’s overseas disclosure program.  But when the IRS assessed its penalty in November, Winfield was stunned to learn that it would be $28,000 — 10 times the amount of tax he owed from 2003 to 2010.  Because the penalty is based on balances when the exchange rate favored the British pound, paying that amount would mean giving up virtually everything he now has in the accounts.”

http://www.reuters.com/article/2013/01/28/us-column-feldman-immigrants-idUSBRE90R10Q20130128

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