All you procrastinators out there, wondering what to do and wondering WHEN to do it?
If you want coverage by the voluntary disclosure program currently under way for unreported bank accounts, you have to get to the IRS before they get to you. I just had one of my applications bounced by the IRS. Audit flag. Client hadn’t been contacted yet.
The deal on these is that my client is no worse off for having applied for the amnesty. The issue was going to come up anyway on the audit, right? So the net result is that now we will have an audit where the penalties for the unreported income and the unreported foreign bank account will be assessed according to regular audit procedures. There is also the theoretical risk of criminal prosecution to deal with.
Memo to all personnel: there is one thing in your control right now. That is the timing of filing your application for amnesty protection. Everything else is out of your control. I would suggest jumping in the pool (metaphorically speaking) immediately. You gain nothing by waiting.