With a weakened squad, and expected to suffer the league's statutory six-point penalty for any club going into administration, the loss of Obst, Ferguson and now Millard - all three of whom started in Saturday's season opener against local rivals Castleford at the Millennium Stadium in Cardiff - are a huge blow to Wakefield coach John Kear.
The IRS may do what it sees as rough justice by calculating statutory FBAR penalties that end up approximating the 27.5% miscellaneous offshore penalty.
You might assume that opting out should reduce your overall penalty exposure below the 27.5% range, but the statutory FBAR penalties after the opt-out might be the same or worse.
Congress expressly denied IRS statutory authority to assess additional tax from taxpayers after 3 years from the date the taxpayer complied with his statutory legal duty to sign and file his non-fraudulent tax return with IRS, under penalty of perjury, with payment of the tax calculated by the taxpayer against his worldwide gross taxable income (WGTI).