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Warren Whitaker proposes changes to the U.S. tax system in an April 2012 Offshore Investment article titled "Restoring Sanity to taxation of US citizens who reside or have accounts abroad." Warren writes that "US citizens who reside abroad are so burdened with US tax requirements and possible penalties that many are considering the surrender of their US passports." To alleviate that burden, he suggests shifting the reporting burden to foreign banks; applying FBAR filing penalties to taxes due rather than account totals; amending the rules establishing non-citizenship; lessening the estate tax; and softening penalties for unreported income in order to encourage return to the tax system.
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