IRS asks a NW taxpayer to enter SDOP and pay 5% as a penalty. In return
what is the taxpayer getting for entering the program versus if the same
taxpayer had done a QD?
In other words, what is the penalty buying the taxpayer?
A QD will bring a taxpayer in compliance. However, the programs
offered by the IRS gives some certainty. Even though streamlined
submissions are still subject to audit, I doubt that many will be
audited.
The QD is more uncertain. The IRS says that it is
looking for QDs that report of foreign bank income and change the Schedule B
foreign bank question to yes and for filings of delinquent or amended
FBARs. So, the chances of audit may be greater.
But for most
taxpayers who are nonwillful, their FBAR penalties are likely not going
to be great if audited, so a QD might be the way to go, particularly if
they are willing to accept a possible higher risk of audit.
For the most effective use of this blog and the links, readers must have the background and skills to test the information by further research and analysis before reaching any conclusion as to its usefulness and correctness in actual situations. Legal advice is always individual, considering the unique facts and circumstances of each client and shaping legal advice and strategies for the particular client. That simply cannot happen on this blog.
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