IRS audit statistics show the agency does not audit many FBARs. Some claim that is “proof” that you can a) file several years of missing FBAR forms and face little risk or b) simply file the current FBAR and hope the IRS doesn’t ask you or your bank
While its true that the IRS has yet to audit many FBAR filings, the IRS has made it very clear that they will pursue those that make quiet disclosures. They have to – few people would pay amnesty penalties if they thought they could get away with a quiet disclosure. I don’t anticipate a big uptick in FBAR audits within the next 12 months but when they happen, things will get ugly. And they will happen; the IRS has the software
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