The IRS calls this method of compliance a “quiet disclosure.”or QD for short.
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 any questions about how long you have held the account.
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 capability of easily identifying those who go the quiet disclosure route.
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