According to the statements made by various IRS officials at a recent American Bar Association conference, the IRS has put in place a program aimed at auditing taxpayers who did a so called “quiet disclosure”. This program will target those who chose not to make a voluntary disclosure through one of the recent Offshore Voluntary Disclosure Initiative in 2009 and 2011, but rather chose to quietly file amended tax returns and FBARs to reflect previously unreported income from their foreign bank accounts. It remains to be seen how aggressive will the IRS pursue these quiet filers, what kind of penalties it will try to go after, and how far back the returns will be audited.
Former IRS Attorneys of Holtz, Slavett & Drabkin can assist you with questions about foreign bank accounts, unreported income and FBARs. We can be reached at (310) 550-6200.