July 27, 2009 - admin

Possible change to FBAR amnesty procedures

Rumor has it that the IRS is re-thinking its procedures for processing voluntary disclosure applications. Yeah, the same old topic – people with hidden offshore bank accounts wanting to Come to Jesus.

Up to now the early dance steps have been:

  1. Written disclosure filed with the local IRS Criminal Investigations unit;
  2. Interview by a couple of Special Agents;
  3. Letter saying you’re eligible (or not) for the program;
  4. ???
  5. Profit!

(Apologies to the Underpants Gnomes).

It appears that the requirement of an intake interview might be eliminated in some cases.  The rumor has the IRS announcing updated procedures as soon as (possibly, hopefully, please-oh-please say yes) this Friday.

Seriously though, my experience has been that the interviews are a formality that add nothing to the process.  It wastes the time of the Special Agents assigned to the case.  The IRS is hunting for names of Rogue Bankers Who Assist Innocent Americans to Evade Taxes.  I would guess that experience so far hasn’t been good.

The fact that the IRS is looking at the amnesty process and making adjustments is good news indeed.  Right now the amnesty seems to be an inflexible tool ill designed to achieve the stated bureaucratic desire.  This is bad for the IRS and bad for taxpayers who want to clean up the mess.

US Real Estate Investments Voluntary Disclosure