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      Whether you’re looking for fun and sun, a peaceful retirement, or the chance to earn some extra income, you’ve got a real world of opportunity open to you… In short, we’ve done our best to narrow down your best options, but only you can decide the right country for you.

      • Spain
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      • Browse All Countries

      Best For:

      • The Best Places To Retire
      • Health Care Abroad
      • Cost Of Living
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      • Safest Places For Retirement
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    • Budgets

      How Much Will It Cost You To Live Overseas?

      The only honest answer is, we have no idea. And neither does anyone else. The only one who can answer that question is you. Here’s the most important thing to understand about budgeting your new life overseas…

      Super Cheap

      • Chitré, Panama
      • Santa Marta, Colombia
      • Phuket, Thailand
      • Dumaguete, The Philippines

      Cheap

      • Medellin, Colombia
      • Boquete, Panama
      • Kyrenia, Cyprus
      • Hua Hin, Thailand
      • The Algarve, Portugal

      Affordable

      • Valencia, Spain
      • Cascais, Portugal
      • Las Terrenas, The DR
      • Pisa, Italy
      • La Rochelle, France
      • Mazatlán, Mexico

      Luxury

      • Ambergris Caye, Belize
      • Kotor, Montenegro
      • The Panama City Beaches
      • Paris, France
    • Resources

      Global Living

      • Living & Retiring Overseas
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      • Foreign Residency & Citizenship
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      • Investing

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      • Home
      • Countries

        Top Destinations:

        Whether you’re looking for fun and sun, a peaceful retirement, or the chance to earn some extra income, you’ve got a real world of opportunity open to you… In short, we’ve done our best to narrow down your best options, but only you can decide the right country for you.

        • Spain
        • Portugal
        • Panama
        • Belize
        • Colombia
        • Cyprus
        • Mexico
        • France
        • Montenegro
        • Browse All Countries

        Best For:

        • The Best Places To Retire
        • Health Care Abroad
        • Cost Of Living
        • Investing in Real Estate
        • Establishing Residency
        • Gun Laws In The World
        • English-Speaking Countries
        • Safest Places For Retirement
        • Best Places In Latin America
      • Budgets

        How Much Will It Cost You To Live Overseas?

        The only honest answer is, we have no idea. And neither does anyone else. The only one who can answer that question is you. Here’s the most important thing to understand about budgeting your new life overseas…

        Super Cheap

        • Chitré, Panama
        • Santa Marta, Colombia
        • Phuket, Thailand
        • Dumaguete, The Philippines

        Cheap

        • Medellin, Colombia
        • Boquete, Panama
        • Kyrenia, Cyprus
        • Hua Hin, Thailand
        • The Algarve, Portugal

        Affordable

        • Valencia, Spain
        • Cascais, Portugal
        • Las Terrenas, The DR
        • Pisa, Italy
        • La Rochelle, France
        • Mazatlán, Mexico

        Luxury

        • Ambergris Caye, Belize
        • Kotor, Montenegro
        • The Panama City Beaches
        • Paris, France
      • Resources

        Global Living

        • Living & Retiring Overseas
        • Raising A Family Abroad
        • Foreign Residency & Citizenship
        • Offshore & Diversification

        Making Money

        • International Real Estate
        • Banking
        • Employment
        • Investing

        Follow Us:

        • Meet Our Experts
      • Real Estate

        Join our Weekly Newsletter
        Overseas Property Alert

        Sign up for our weekly newsletter to receive expert insights on the best international real estate investment opportunities.






          We Value Your Privacy! We will not share your email address with anyone else, period.

          Buying Real Estate For Cashflow

          • Discover tips and strategies used by global property investing veterans

          Explore Our Latest Posts

          • Learn how to invest and purchase property abroad…

          Go To The Overseas Property Alert Site

          • How To Become Independently Wealthy And Fund The Lifestyle Of Your Dreams
        • Conferences

          Upcoming Events

          • Explore Our Events Site

          International Property Summit

          Caribbean Virtual Conference

          Live and Invest In Spain Conference

          PANAMA CITY, PANAMA

          June 18-20, 2025

          VIRTUAL

          July 17-19, 2025

          Valencia, Spain

          Sep. 17-19, 2025

          LEARN MORE
          LEARN MORE
          PRE-REGISTER
          LEARN MORE
          PRE-REGISTER
          • MORE EVENTS

          Contact Our Events Team

          Toll-Free U.S. and Canada:
          1 (888) 627 8834
          From Outside North America:
          1 (443) 599 1221
          Working Hours
          Monday – Friday 08:00 am – 17:00 pm EST.

          Reach us with your questions by email at: events@liveandinvestoverseas.com

        • Store

          Unlock The World

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          Overseas Havens Reports

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          • Explore Our Store
          Your passport to a life well-lived abroad

          Services

          overseas living letter offers affordable retirement guidance
          The Simon Letter Wealth Protection Insights
          Global Property Advisor Global Investment Opportunities

          Our Customer Service team is here to assist with any questions or concerns CustomerService@LiveandInvestOverseas.com

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        Live and Invest Overseas
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          Home Taxes

          Good News For Those Who File The FBAR

          Justice Done

          by Lief Simon
          Mar 29, 2023
          in Taxes
          0 0
          Money coins stack growing graph and piggy bank

          Adobe Stock/N_studio

          Do you file the FBAR? A few weeks ago, the United States Supreme Court handed down an important judgment… It didn’t make many headlines…

          You won’t have seen it on the front page of most newspapers… unlike other controversial Supreme Court cases, like the Dobbs decision on abortion last year, or the case against the Biden administration’s student debt forgiveness scheme.

          But, for American taxpayers who live and work overseas, the ruling in Bittner v. United States is a big deal…

          The case involved one Alexandru Bittner, who holds both U.S. and Romanian citizenship.

          He immigrated to the States in the 1980s and obtained U.S. citizenship, but moved back to Romania in 1990.

          In the following two decades, Bittner made more than US$70 million from investments, including real estate and securities.

          He held multiple foreign bank accounts… But as a U.S. citizen, he could not escape his U.S. tax obligations, even though he lived abroad (and held dual citizenship).

          Now, this should set alarm bells going in your brain, dear reader.

          Let’s say a U.S. person holds US$10,000 in a foreign bank account (or across multiple accounts) at any point during the calendar year, he’s required to report that money by filing an FBAR (Foreign Bank and Financial Accounts form)…

          Failure to report can mean big penalties

          Originally, the FBAR law (which dates to 1970) was only meant to penalize “willful” violations—in other words, if you purposefully do not report the account information.

          But in 2004, Congress amended the law so it also included “non-willful” violations. So, you could be punished even if you only accidentally failed to report.

          The penalty for willful failure to report is US$100,000, while a non-willful failure carries just a US$10,000 fine…

          Bittner claimed not to know about the filing requirement and did not file any FBARs until 2012.

          The IRS accepted that Bittner did not know about the filing requirements and therefore his violations were “non-willful.”

          However, they still slapped a gigantic fine on him: a total of US$2,720,000.

          This was a very simple calculation by the IRS: Bittner had made 272 separate violations of the law, since he failed to report 272 accounts between 2007 and 2011. (Bittner’s failures to file prior to 2007 were not counted, thanks to the statute of limitations.)

          US$10,000 multiplied by 272 equals US$2.72 million.

          Bittner objected (who wouldn’t) and took the case as far as the Supreme Court…

          Start Your New Life Today, Overseas






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            Was It 5 Violations—Or 272?

            Bittner argued that the penalty, as written in the law, applies to each failure to file an FBAR, not to each account…

            So, even if he owned 177 foreign bank accounts (the number he admitted to) between 2007 and 2011, with more than US$10,000 in them… the number of accounts didn’t matter.

            You only have to file one FBAR per year—not one per foreign bank account.

            So, Bittner argued he should be penalized five times over—one for each year he failed to file an FBAR—not hundreds of times over, for each account he failed to report…

            He argued, essentially, he should be punished for the five forms he failed to fill out, not the hundreds of accounts he failed to report…

            Five times US$10,000 is of course a much smaller amount to have to pay…

            Good News For Taxpayers (For Once)

            In a 5 to 4 ruling on Feb. 28, the Supreme Court sided with Bittner: The US$10,000 penalty applies per failure to file an FBAR, not per foreign account.

            So, American expat groups around the globe celebrated the decision…

            It’s good news for people with offshore bank accounts… and really for all taxpayers, I think, as it’s a slap on the wrist for the IRS.

            The IRS approach to raising money through excessive penalties isn’t on solid ground.

            At a minimum, it’s a good thing for people who are simply unaware of the FBAR filing requirements who get caught up in these things…

            My own personal view is that the IRS will decide from now on that all violations are “willful” and seek the maximum US$100,000 penalty.

            But Alex Bittner just saved himself US$2.67 million by taking his fight to the highest court in the land…

            Good for Alex.

            Stay diversified,
            Lief Simon signature
            Lief Simon
            Editor, Simon Letter

            Tags: 'FBAR''Taxes'Americans Overseasfile fbarLive abroadTax
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            Lief Simon

            Lief Simon

            Lief Simon has lived and worked in 7 countries on 5 continents and traveled to more than 75 countries. His real estate investment career began with a $5,000 down payment on a three-flat building in Chicago. Less than three years later, Lief sold the building for a leveraged return of 3,000%—$150,000 in profit after closing costs and commissions.

            From there, he turned his attention overseas and has bought property in 24 countries including France, Croatia, Portugal, Ireland, Belize, Spain, Argentina, Cyprus, Romania, and beyond. Thanks to his decades-long career as a global property investor, Lief has built a multi-million-dollar portfolio that includes rental properties, significant land holdings, and 7 personal residences.

            Lief has established residency in 3 countries and acquired a second passport from Ireland.

            In 2008 Lief and wife Kathleen Peddicord made the most important investment of their lives—a 215-acre oceanside finca, known as Los Islotes. There, on Panama’s largely undiscovered Veraguas coast, they’ve installed underground electricity, water, and internet and built a forever family home that sits at the heart of their ultimate vision: a gold standard private residential community for those in search of a true safe haven escape.

            Lief’s latest book, “Cowboy Millionaire—The New American Pioneer,” collects all the wisdom he has learned in three decades of living and investing outside America.

            He offers advice on international diversification in his twice-weekly Offshore Living Letter and monthly Simon Letter dispatches. For real estate investment opportunities, check out his monthly Global Property Advisor service.

            If you’d like to meet Lief in person, join him for one of our upcoming in-country conferences. You’ll find further details here.

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                  We Value Your Privacy! We will not share your email address with anyone else, period.
                  HOME

                  Top Countries

                  • Spain
                  • Portugal
                  • Panama
                  • Belize
                  • Colombia
                  • Cyprus
                  • Mexico
                  • France
                  • Montenegro

                  Best For:

                  • Health Care Abroad
                  • Retirement Living
                  • Cost Of Living
                  • Investing in Real Estate
                  • Establishing Residency
                  • Gun Ownership
                  • English Speakers
                  • Safety
                  BROWSE ALL COUNTRIES

                  Budgets

                  How Much Will It Cost
                  To Live Overseas?

                  Super Cheap

                  • Chitré, Panama
                  • Santa Marta, Colombia
                  • Phuket, Thailand
                  • Dumaguete, The Philippines

                  Cheap

                  • Medellin, Colombia
                  • Boquete, Panama
                  • Kyrenia, Cyprus
                  • Hua Hin, Thailand
                  • The Algarve, Portugal

                  Affordable

                  • Valencia, Spain
                  • Cascais, Portugal
                  • Las Terrenas, The DR
                  • Pisa, Italy
                  • La Rochelle, France
                  • Mazatlán, Mexico

                  Luxury

                  • Ambergris Caye, Belize
                  • Kotor, Montenegro
                  • The Panama City Beaches
                  • Paris, France

                  Resources

                  Global Living

                  • Living & Retiring Overseas
                  • Raising A Family Abroad
                  • Foreign Residency & Citizenship
                  • Offshore & Diversification

                  Making Money

                  • International Real Estate
                  • Banking
                  • Employment
                  • Investing
                  Meet Our Experts

                  Real Estate

                  Overseas Property Alert 

                   

                  How To Become Independently Wealthy And Fund The Lifestyle Of Your Dreams

                  VISIT SITE

                  Buying Real Estate For Cashflow

                   

                  Discover tips and strategies used by global property investing veterans

                  READ MORE

                  Explore Our Latest Posts

                   

                  Learn how to invest and purchase property abroad…

                  EXPLORE

                  Conferences

                  INTERNATIONAL PROPERTY SUMMIT

                  PANAMA CITY, PANAMA June 18-20, 2025
                  LEARN MORE

                  CARIBBEAN VIRTUAL CONFERENCE

                  VIRTUAL July 17-19, 2025
                  LEARN MORE
                  PRE-REGISTER

                  Live and Invest In Spain Conference

                  Valencia, Spain Sep. 17-19, 2025
                  LEARN MORE
                  PRE-REGISTER
                  MORE EVENTS

                  Contact Our Events Team:

                  Toll-Free U.S. and Canada:
                  1 (888) 627 8834

                  From Outside North America:
                  1 (443) 599 1221

                  Working Hours
                  Monday – Friday 08:00 am – 17:00 pm EST.

                  Reach us with your questions by email at: events@liveandinvestoverseas.com

                  Store

                  Overseas Havens Reports

                  • Expats' comprehensive destination guides

                  Conference Kits

                  • Hours of coverage  from our latests conferences

                  Lahardan Books

                  • Titles on living and investing around the world

                  Services

                  • Overseas Living Letter: Affordable Retirement Guidance
                  • The Simon Letter: Wealth Protection Insights
                  • Global Property Advisor: Global Investment Opportunitites
                  VISIT OUR STORE

                  Free Report

                  THE 10 BEST PLACES TO RETIRE IN 2025

                  FREE REPORT: The 10 Best Places To retire in 2025

                  Sign up to receive the FREE daily e-letter, Overseas Opportunity Letter and we’ll immediately email you our editors’ latest research report…






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