I just talked to someone at the IRS office in Philadelphia about some voluntary disclosure client matters. I have a pipeline of these things going right now. All the cool kids are turning themselves into the IRS, reporting their offshore bank accounts, and paying their taxes!
Anyway, there isn’t much guidance in this area at the moment. The gentleman at the IRS said they are about to publish a second FAQ which will answer a lot more questions. So stand by. As soon as I get a copy I will link to it.
Phil…I can see why they are running to pay their taxes! The IRS latest rhetoric is that they know there is a significant amount of non-compliance in the FBAR area. I believe the potential penalties can be devastating and the recently announced Voluntary Disclosure initiative could greatly reduce the penalties (compared to what may result if taxpayers don’t come forward and are identified by the IRS).
Please let us know when the 2nd FAQ comes out.