September 18, 2009 - Phil Hodgen

Only noncompliant years are considered for the amnesty so file stuff fast

If you are in the amnesty program or planning to be in it, you know about the “20% of high balance” penalty that the IRS will drop on you because you were a Bad Dog.  As you might guess, I Have Opinions about the smartitude of the IRS brass and their strategic decision on setting the penalty so high.  But I digress.

The “20% of high balance” penalty only applies to years that are “out of compliance.”  If there is any way humanly possible for you to get TD F 90-22.1, Form 3520, etc. filed before the 23rd, I suggest you do it.  Take as many years off the table as you can.

Not that you’d necessarily WANT the amnesty deal.  But you might as well engineer everything towards the optimal result.

Right now we are reaching out to ALL of our amnesty clients and making sure that as much as possible they have their paperwork in.  It will be a busy weekend.  That’s why we’re not taking on any new amnesty work.

Voluntary Disclosure