July 29, 2009 - Phil Hodgen

New procedure for starting FBAR disclosures

The IRS is changing the way this is done.  My guess?  Too much paperwork.  They need triage to sort the voluntary disclosures into the “Woo hoo! We landed a big one!” pile and the “Meh, that’s boring!” pile.

We have finally migrated to a formal letter with actual information being asked.  This should eliminate the need (in many cases) for the initial interview that has been conducted up to now by the Special Agents.

You can download the IRS letter as a Word document, straight from

We’re doing a lot of these voluntary disclosures to the IRS. Four months into the six-month amnesty, we’re getting some clarity on how the IRS wants to do them. ooooooKay.

Call me at +1-626-437-2500 if you want to talk about this process and how we can help you.

UPDATE: a call to the Supervising Special Agent of one of the offices we are dealing with revealed a crucial piece of information: filling in and filing this form is in lieu of the interview. You don’t go through the interview with Criminal Investigations if you do this paperwork.

US Real Estate Investments Voluntary Disclosure