Publication 54. Gee, that sounds like the name of a science fiction story......or a mystery full to the brim of political intrigue.

Nothing could be further from the truth. Ever hear of the 'Tax Guide for U.S. Citizens and Resident Aliens Abroad'? This year's edition, 'For use in preparing 2012 Returns', was published on 6 December 2011, is 44 pages long and can be found on the IRS website. If you do not feel like reading the rest of this article, then here is an executive summary: Other than omitting anything about the infamous F(u)BAR forms - a grievous mistake if ever there was! - Publication 54 is the next best source of information for the overseas US tax filer.......if you really are masochistically inclined and want to read about US taxes after a hard day of work, then read my books first - they are better and funnier than anything the IRS could possibly assemble!

Now if you are a US expat or green card holder, you really should be looking at this document (Publ 54). It is the ONLY means of uniformly informing the US tax filer overseas about his or her obligations. The ONLY means, unfortunately, absolutely no one has ever heard of it....and while the IRS website (www.irs.gov) is free, just try to find anything there - more people give up because it is simply not worth the effort.

Don't go thinking that I'm saying that no one knows about Publication without doing some research: I selected 10 tax clients of mine who are reasonably astute and who promptly return emails. I asked them each if they'd ever heard of Publication 54. 'No' was the unanimous answer to the question - and getting ten clients of mine to agree about anything, unanimously, is no easy task!

Every so often, I like to be a little less cynical - now is that time: Publication 54 is actually a good, comprehensive publication. It should be looked at by every overseas dwelling US tax filer - in addition, of course, to my annual Tax Guide for Expats!

So here's a simple question I ask: Why hasn't the IRS really bothered to promote Publication 54? The sad fact of the matter is that the IRS has absolutely no idea how to pleasantly communicate - fear tactics are not the best public relations for getting a group of people to be interested in educating themselves about tax law.

Publication 54, F(u)BAR and the Isaac Brock Society

I never heard of the Isaac Brock Society until a few days ago, when an article on their website made it to the professional group of US tax specialists who I 'liaise' with as a member of American Citizens Abroad. The Brock Society members apparently started out as dual filing Canadians/Americans who are a bit 'disgruntled' with the IRS. http://isaacbrocksociety.ca. It has expanded as disgruntlement has spread far and wide beyond the borders of North America.

That website had a wonderful critique of F(u)BAR and Publication 54, which I will comment upon throughout the balance of this article.

Section 361b of the Patriot Act requires the Secretary of the Treasury to report, annually, to Congress on efforts to improve F(u)BAR compliance. The Brock Society article states that reports for years 2001, 2002 and 2004 are available for your reading delight at http://www.fincen.gov/news_room/rp/reports_congress.html If you've got absolutely nothing better to do, take a look. Have any members of Congress read any of them? None of the members of Congress who I know has read any of these compliance reports....a situation far more normal than anyone can imagine- this is why there are large Congressional staffs - it is the staffers who do the reading and if the printed material has little to do with congressional district matters, it is open to conjecture if any domestic staffer has read - or cares - or even knows of - F(u)BAR.

Years 2002 - 2010? They were simply not available until now. Want to access them? Then carefully type in: https://docs.google.co,m/folder/d/0B9jAp0ZcF0AQZ3kwLUFRendfWm8/edit?pli=1 One comment: If the U.S. government really wanted you to see these reports, then they would have made accessibility a heck of a lot easier!

And now for some Brock Society commentary about this year's report. There were six issues brought up. I'll summarize and comment upon five matters, combining my comments into two areas:

* The reports uniformly mention the fact that 'the Internal Revenue Service agreed to take responsibility for assessing whether better education and guidance regarding the requirements to file an FBAR (that's their spelling, not mine! Me? It's F(u)BAR!) was needed and if so, to implement recommended improvements.' Does anyone honestly think the IRS has been successful in reaching the people about what the obligations of the US tax filing populous are? And how many of you think that the IRS has even tried to do this?

* Who has to file the F(u)BAR? The report states that the IRS should be working to 'Develop additional methods to identify persons who may have an obligation to file FBARs'. The Brock Society points out that it does not take much brain power to figure out that immigrants and expats probably comprise close to 90 percent of individuals required to file. Now I truly cannot speak knowledgeably about recent immigrants to the U.S. and their bank accounts but I think I can speak with some authority about the expat and living as an American, overseas. We, the expats, have learned not to expect anything from the US Consulates and Embassies regarding taxation. The lack of knowledge in the subject is not surprising but the lack of forms for filing is a sad deficiency. Thus, using the resources of the US Foreign Service would probably not be an efficient way of communications (although, to be frank, it would be better than virtually nothing at all, which is the current reality).

Ever hear of AmCham - The American Chamber of Commerce? What about the American Women's Clubs throughout the world.....or the American schools overseas. What would it take for the IRS to write a pleasant, non-intimidating letter to be sent to every relevant expat organization throughout the world, asking for help, explaining, as simply as possible, that the expat is responsible for tax obligations he or she might not have been aware of and that the IRS wants to help the expat in this matter.

For a fraction of the costs that are probably already being spent, the IRS could truly make an attempt to communicate. Yeah, we probably will discover an inordinately large amount being spent to publicize 'the program', only no one has really gotten the message.

And let us get back to Publication 54. I just downloaded and printed out the 44 page 2012 edition. I looked at all the pages and perhaps I am simply missing it but I cannot find any mention of F(u)BAR in the 2012 edition. Wouldn't one presume that a booklet titled "Tax Guide for US Citizens and Resident Aliens Abroad" would devote some space (including a sample copy of a filled out TDF90.22-1, as other forms were printed) to this matter? Could anyone answer this one logically??

According to the Brock Society website, Publication 54 mentioned F(u)BAR for the first time in its 2009 issue. It's prior issue was, in essence, a combined piece for 2007 and 2008. Thus, it appears that this booklet was not 'high priority', previously. Now? It is open to conjecture.....But you know what? Publication 54 is not that bad a read - Oh, it's definitely boring in the same way that most writings on taxation are boring (except for mine and DP Sengupta's , of course!) but it is informative and carefully thought out.....and including samples of filled out forms is a definite advantage!

If the IRS truly wants to inform the 5-7 million people who are presumed to be liable for annual filings then it has to do something. As of now, all the monies that the US government says it has put into an information program is worthless - a complete waste of time and money.....except for Publication 54.....! Expand it to include F(u)BAR and truly figure out how to get it out there and perhaps you will get a better response from those who are obligated to file. This is common sense. The question now is: Can the IRS prove that it can function with common sense?