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2 thoughts on “What Should You Do If You Have Unfiled FBAR Forms?

  1. Hi there, thanks for your very informative article. I would appreciate your opinion. I am resident in the UK since 2007 and have filed tax returns with IRS every year. I have not had any US income or tax liability in those years, all my income is taxed in the UK. However, I was unaware of the FBAR until very recently and am currently preparing my return for 2013. If I now file FBARs for the previous years, do you think I can go for the “Quiet Disclosure” option you mention? Thanks, BD

    1. Hi Brendan, there is always a risk with “quiet disclosure” as it is discouraged by the IRS. The extent of the risk depends on the extent of your account values. However, given that you have filed a US tax return you are likely at higher risk of being considered a willful non-filer. The decision on how to file is a complex one and should be based on the facts of your situation and a thorough analysis and legal review – the risk of penalty shouldn’t be downplayed.

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      Best regards,

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