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Huge Issues with FBAR and 8938

Huge Issues with FBAR and 8938

Old Dec 17th 2021, 9:42 am
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Unhappy Huge Issues with FBAR and 8938

Need some advice from anyone who might have been through a similar situation before.

Situation :
- Moved to the US in Jan 2017.
- Started working in Jun 2017.
- I asked friends and colleagues how to file my tax returns and everyone just said use TurboTax so I filed first tax return using TurboTax (as I thought it was a simple case). Did not recall being prompted to report foreign income or assets.
- Engaged AmeriTax to do my 2018 return just to see if I was doing everything right - did not uncover any additional filing requirements foreign or otherwise.
- Continued in 2019 and 2020 to file using TurboTax.
- Recently found out about FBAR and 8938 (like just last week) and I am now very worried. I have not filed either of these since 2017.
- Having previously worked in multiple countries prior to moving to the US I have many bank accounts (less than 25) and a government forced retirement savings account. I also hold a small amount of stocks in 3 companies with yearly dividends (not large amounts of a couple hundred dollars per company). Total amount of interest across all accounts is less than $100 + total dividends is less than $750 USD per year (dividends already taxed in foreign country). This was mistakenly not reported in my tax returns. I have not needed to file FBAR/8938 equivalents in the other countries I had worked and had somehow overlooked it this requirement here. I feel really stupid right now.
- I had sold my house prior to arriving in the US so those funds from the sale were in one of the foreign bank accounts for the first quarter of 2017 until I bought a house in the US.
- Spoke to a CPA and was advised that to correct this, I need to go down the Streamlined route - which means filing late FBARs, 8938s and amended 1040s a penalty of 5% - which would equate to around $50K (in my case because of the sale of my house prior to arrival in the US) - not an ideal case. I barely have that much cash on hand now since I used those funds to buy a house in the US. The CPA fees quoted around $5K. I asked about the delinquent path - and I was told it was no longer an option.

I have a stack of questions if anyone can help shed some light with similar recent experiences (hopefully successful) that would be greatly appreciated.

1) I have read on this forum some people being told the same thing by their CPA about Streamlined procedures being the only option, but instead went on to file late FBARs, 8938s and amended 1040s for the prior years without going through the Streamlined procedures to avoid the 5% penalty.
a) Is filing deliquent/late FBARs/8938s/amended 1040s (instead of doing Streamlined procedures) a viable option for me (hoping to avoid the 5%)?
b) Has anyone recently does this before?
c) Are there any other penalties I might incur?
d) Noticed that FBAR is under FinCEN but FBAR is also mentioned on the IRS website. How does FBAR relate to IRS? How many potential penalties are there? Late FBAR penalty? Late 8938 penalty? amended 1040 penalty? Penalties from FinCEN? Penalties from IRS?
e) Has anyone ever gone through a similar situation without penalty?
f) Has anyone ever gone through a similar situation with penalties? And if so, what were your penalties?
h) How long does it take to know whether you're going to receive a penalty?
i) Has anyone gone down the Streamlined path, paid the 5%, and then asked for forgiveness and received a refund of the penalty? CPA suggested that there is a small possibility of success doing this.

2) I would like to correct this ASAP and become 100% compliant before IRS contacts me. Should I just call IRS and let them know my situation and my intent to fully resolve this big mistake?
Some late FBAR CPA/Attorney websites are saying never contact IRS - 'come to us' first - is this just a scare tactic?

3) In the FBAR form there is this section "If this report is being filed late, select the reason for filing late". None of the suggested answers really fit my scenario. What should I write in the Other section to prove that I was Non-willful? Does anyone know how IRS determines Willful vs Non-Willful? I definitely did not willing get myself into this situation, but I am just wondering how IRS casts judgement on this.

4) I am worried that the penalties are going to be more than I have on hand.
a) Is the First Time Penalty Abatement (FTA) a potential route that I can pursue?
b) Has anyone successfully used FTA?
c) Is there a way of paying penalties by installments?

5) After uncovering this nightmare of FBAR/8938s, I really want to consolidate/close as many accounts as possible to reduce the burden of future paperwork.
a) Is it advisable to do this before filing late FBARs/8938s? Or will this just raise unnecessary suspicion?
b) If I transfer large amounts >$10K from my foreign bank accounts to the US, do I need to declare anything to IRS prior - to prove that the funds are my own savings and not additional income?

6) My CPA is asking for Power of Attorney. Is that normal? What should I do?

Dumb questions ...
7) Does a forced foreign government retirement fund (that I can't touch until 65) need to be reported on FBAR?
a) If so, do I just report this in section 2 as another Financial Account other?
b) I have not contributed to this fund since 1999 but it is still making small gains - do these gains need to be reported as income in 8938/amended 1040?

8) When submitting FBARs, if I had already consolidated some of my foreign bank accounts (close one transfer to another). How do I report this in FBAR? Report both accounts? Max value in each? How do I avoid double reporting the same funds?

9) I know that late FBARs can be submitted online but for the 8938s and amended 1040s can these also be submitted online?

10) When filing FBAR, 8938
a) Do we need to submit supporting banking statements? If not, how long do we need to keep the supporting banking statements for?
b) How do you deal with missing statements, is it ok to estimate the values (even if it is over estimate)? eg. Max account value of account in a prior year would be equal to or less than the current year because nothing else was added to the account except minor interest of a few dollars.

11) If one of my foreign credit card accounts has a positive balance of $100, does this need to be reported in FBAR/8938?

12) I only have normal bank accounts, some standard shares, and a forced government retirement fund. Do I leave Part IV and V blank on the FBAR form?

13) Item 45 on the FBAR form what is Filer Title?

14) Do I submit 1xFBAR, 1x8938 and 1x1040 amended for each missing year? Just want to be sure.

15) When filing late FBAR, can I submit 2020 first, then subsequently 2019, 2018 and 2017 as I retrieve information from the banks? Or must it all be done at the same time?

16) Can I submit late FBAR first, then take care of the late 8938 and 1040 in subsequent days/weeks, or does it have be all be presented at the same time?

17) Does anyone ever submit a cover letter and statement of facts to explain your situation and the submitted documents? If so, how did you submit it? Online? Snail mail? Who did you address it to?



Sometimes I wonder why they just didn't make this a mandatory requirement before migrating to the US to declare all foreign assets. Would have saved me and I guess a lot of other people a lot of pain.

Thank you in advance for any help you may be able to provide.

Last edited by Nick12; Dec 17th 2021 at 11:07 am. Reason: Added correction
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Old Dec 17th 2021, 1:07 pm
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Default Re: Huge Issues with FBAR and 8938

Gosh, lots of questions. Here are some answers.

1a, 1b and 1c. This is called a quiet disclosure, and people have done this in the past, however for several years now the IRS has specifically stated on their website that this is not an option. Doing this potentially puts you in a much worse situation that you are in now with MUCH larger penalties than you already face.

1d. FBAR penalties for late filing can be up to 50% of the account value for EACH year you held the account for up to 6 years, the penalty actually applied varies but the point is that it can wipe out your savings and then some. The IRS penalties are $10,000 for each missing 8938 and go up from there if you fail to provide it after you have been notified of the issue. Penalties for underpayment t of tax are 40% of the tax due plus interest.

1e, 1f, 1g, 1i. Unlikely that anyone has avoided a penalty in the recent past now that they have streamlined programs to resolve the situation. The streamlined process takes quite a long time, many months to several years.

2. They are giving you good advice. Get professional advice and representation before you declare your situation to the IRS.

3. Willful is when you knew about the requirement and did not comply. Non willful is when you did not know. You may have been non willful up to this point but since you now know about the requirement you are willful from this point forward. You need to resolve this ASAP.

4a, 4b, 4c. No first time abatement. You can always work out a payment plan with the IRS but you will pay interest at healthy rates.
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Old Dec 17th 2021, 1:21 pm
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Default Re: Huge Issues with FBAR and 8938

5. When you consolidate accounts won’t make any difference. You are unlikely to be challenged on that unless it is a regular occurrence but I would keep records and statements just in case.

6. I would not give a stranger POA!

7. It is safest to report pensions of any kind on your FBAR and Form 8938. No one ever got into trouble for over reporting. Report as other accounts. No need to declare income within a pension until you take it as income. Beware that the IRS does not recognize ISAs so that is all taxable and income must be declared.

8. If you transfer money from one fund to another you have to report it twice under each fund as it contributes to the max value of each fund.

9. 1040s can be amended online, but in your case you have so many issues you will need to go through a paper process.

10. You don’t need to supply statements with the FBAR or 8938 but must keep them and present if they request them. If you don’t have statements make every effort to get them, most financial institutions can provide past records for many years (for a fee). If that fails be able to back up that you attempted this and use your best estimate instead with justification for how you arrived at that number. You cannot just use last years value, you have to adjust for the exchange rate on each year.
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Old Dec 17th 2021, 1:28 pm
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Default Re: Huge Issues with FBAR and 8938

11. Unlikely. $100 is the least of your problems.

12. Yes

13. Don’t have the form in front of me, but probably your name, Mr, Mrs, etc or if a company your position.

14. Yes

15. 2017 thru 2020 are all now late so I would submit them all together, which if you are doing the streamlined process you will have to do.

16. Do them all at the same time,

17. You submit your justification for being delinquent at the same time you submit all your past FBARs , 8938s and tax forms.
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Old Dec 17th 2021, 1:41 pm
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Default Re: Huge Issues with FBAR and 8938

I sympathize with you, it is a very bad situation. You are not alone, many people have fallen into this situation. Sometimes there are other options depending upon circumstances but In your case my very strong advice is to go with a professional and do the streamlined process. Bad as that is, doing anything else could put you in a MUCH worse situation. I have used Turbo Tax for many years and can assure you that for quite a few years now, certainly since 2017, it has asked if you have foreign investment or savings and it does advise that you need to complete an FBARand 8938, so it will be hard to argue you were unaware of the requirements. Plus, it is publicized everywhere, and in any case in the IRS world it is your responsibility to be aware of all tax requirements. Ignorance of the law is not a recognized defense.

The penalties for the streamlined process are outrageous, particularly since so many people find themselves in this situation by accident. However the penalties for doing anything outside of the streamlined process can potentially wipe out all of your foreign savings and still leave you owing the IRS, so not a good road to travel.

Dont delay in resolving this, time is not your friend in this situation.

I AM NOT A TAX PROFESSIONAL.

Last edited by Glasgow Girl; Dec 17th 2021 at 1:51 pm.
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Old Dec 17th 2021, 3:36 pm
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Default Re: Huge Issues with FBAR and 8938

Originally Posted by Glasgow Girl View Post
I sympathize with you, it is a very bad situation. You are not alone, many people have fallen into this situation. Sometimes there are other options depending upon circumstances but In your case my very strong advice is to go with a professional and do the streamlined process. Bad as that is, doing anything else could put you in a MUCH worse situation. I have used Turbo Tax for many years and can assure you that for quite a few years now, certainly since 2017, it has asked if you have foreign investment or savings and it does advise that you need to complete an FBARand 8938, so it will be hard to argue you were unaware of the requirements. Plus, it is publicized everywhere, and in any case in the IRS world it is your responsibility to be aware of all tax requirements. Ignorance of the law is not a recognized defense.

The penalties for the streamlined process are outrageous, particularly since so many people find themselves in this situation by accident. However the penalties for doing anything outside of the streamlined process can potentially wipe out all of your foreign savings and still leave you owing the IRS, so not a good road to travel.

Dont delay in resolving this, time is not your friend in this situation.

I AM NOT A TAX PROFESSIONAL.
On Turbo tax it may be the level selected, but that seems strange as foreign accounts are not business, Premier and above deals with investments so maybe it’s missing from free and deluxe. The more you pay for it the more more forms it includes… I feel like it has always asked me… but I have always had to basically use the most expensive version of it.
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Old Dec 17th 2021, 3:39 pm
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Default Re: Huge Issues with FBAR and 8938

Glasgow Girl has given you good information. Be wise and follow what she has suggested. Above all, get professional help to resolve this - You're in a bad place and won't be able to untangle this yourself effectively.

As mentioned, Turbotax does state that you may have reporting requirements for FBAR and 8938 every time you use it (after answering the questions about having foreign accounts). You should not ignore the advice it's giving you. It's doing you a favor.

I fell foul of the FBAR reporting many years ago, but that was after it was newly introduced. There was a period of time where you could correct the matter with back dated FBAR forms and no penalty, since they had some sympathy for people not knowing it was a requirement, but that time has since expired. A well written letter of explanation may get you some relief.

Best of luck.....and as mentioned.....waste no time getting this fixed.
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Old Dec 18th 2021, 9:50 am
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Default Re: Huge Issues with FBAR and 8938

Firstly, thank you so much for the speedy and detailed response. Much appreciated.

Originally Posted by Glasgow Girl View Post
Gosh, lots of questions. Here are some answers.

1a, 1b and 1c. This is called a quiet disclosure, and people have done this in the past, however for several years now the IRS has specifically stated on their website that this is not an option. Doing this potentially puts you in a much worse situation that you are in now with MUCH larger penalties than you already face.
Just a follow up question to this. If ALL late FBAR/8938/amended 1040 forms are submitted, then isn't this called a delinquent submission? I thought silent submissions were when someone just reports only for the current year and fails to report the missing years.

Originally Posted by Glasgow Girl View Post
1d. FBAR penalties for late filing can be up to 50% of the account value for EACH year you held the account for up to 6 years, the penalty actually applied varies but the point is that it can wipe out your savings and then some. The IRS penalties are $10,000 for each missing 8938 and go up from there if you fail to provide it after you have been notified of the issue. Penalties for underpayment t of tax are 40% of the tax due plus interest.
Out of interest, have you read of or know anyone who has received the maximum penalties for this? Did they do something really bad? In my case, the amount of additional tax I missed on paying would amount to only hundreds of dollars, and obviously failure to file was my mistake. I know it was not right, but it far from cheating the IRS out of lots of tax money. Is it normal/fair for IRS to apply full penalties in such a case?

Originally Posted by Glasgow Girl View Post
1e, 1f, 1g, 1i. Unlikely that anyone has avoided a penalty in the recent past now that they have streamlined programs to resolve the situation. The streamlined process takes quite a long time, many months to several years.
My accountant quoted 45 days to submit my case - I have all my information pretty much ready to submit, just chasing some older banking statements. When you mention several years, what type of situation are you referring to?

Originally Posted by Glasgow Girl View Post
2. They are giving you good advice. Get professional advice and representation before you declare your situation to the IRS.
Is it bad to contact IRS directly and apologise for my oversight and then assuring them that I would take all necessary measures to become compliant as soon as possible? I would have thought me coming forward voluntarily would be the right thing to do - whether I engage a CPA or not.

Originally Posted by Glasgow Girl View Post
3. Willful is when you knew about the requirement and did not comply. Non willful is when you did not know. You may have been non willful up to this point but since you now know about the requirement you are willful from this point forward. You need to resolve this ASAP.
Absolutely agree, I am fully committed to getting 100% compliant. I have never before been in a situation like this as I am usually ultra thorough with my dealings with tax agencies. Unfortunately I let my guard down in this instance.

Originally Posted by Glasgow Girl View Post
4a, 4b, 4c. No first time abatement. You can always work out a payment plan with the IRS but you will pay interest at healthy rates.
Do you know when FTA can be used and for what?

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Old Dec 18th 2021, 10:01 am
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Default Re: Huge Issues with FBAR and 8938

Thank you again for addressing all of my questions - I really appreciate it.

Originally Posted by Glasgow Girl View Post
5. When you consolidate accounts won’t make any difference. You are unlikely to be challenged on that unless it is a regular occurrence but I would keep records and statements just in case.
Just wanted to make sure it doesn't look like I am trying to hide anything in closing some accounts. I just want to reduce overseas footprint for future FBAR/8938 filings. In hindsight, I should have done this before I arrived.

Originally Posted by Glasgow Girl View Post
6. I would not give a stranger POA!
He says he needs submit items on my behalf to IRS. I think it would be this form - Form 2848, Power of Attorney and Declaration of Representative.

I am also hesitant to assign POA to anyone. What other options do I have?

Originally Posted by Glasgow Girl View Post
7. It is safest to report pensions of any kind on your FBAR and Form 8938. No one ever got into trouble for over reporting. Report as other accounts. No need to declare income within a pension until you take it as income. Beware that the IRS does not recognize ISAs so that is all taxable and income must be declared.
Noted. But each account I add increases the 5% penalty.

Originally Posted by Glasgow Girl View Post
8. If you transfer money from one fund to another you have to report it twice under each fund as it contributes to the max value of each fund.
Understood, but it is the same money. It would then increase the 5% penalty. Surely there is a way to not double count this.

Originally Posted by Glasgow Girl View Post
9. 1040s can be amended online, but in your case you have so many issues you will need to go through a paper process.
The changes I would need to make is add some interest <$100 per year and some dividends <$750 (already taxed in foreign country) per year.

Originally Posted by Glasgow Girl View Post
10. You don’t need to supply statements with the FBAR or 8938 but must keep them and present if they request them. If you don’t have statements make every effort to get them, most financial institutions can provide past records for many years (for a fee). If that fails be able to back up that you attempted this and use your best estimate instead with justification for how you arrived at that number. You cannot just use last years value, you have to adjust for the exchange rate on each year.
I can get a written statement from a bank representative with the maximum value of the account from that year and the interest paid to the account. Would that suffice?

Last edited by Nick12; Dec 18th 2021 at 10:22 am.
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Old Dec 18th 2021, 10:09 am
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Default Re: Huge Issues with FBAR and 8938

[QUOTE=Glasgow Girl;13082010]11. Unlikely. $100 is the least of your problems.

12. Yes

13. Don’t have the form in front of me, but probably your name, Mr, Mrs, etc or if a company your position.

Found out what it was. 'Parent/Guardian' if submitting for a child.

Originally Posted by Glasgow Girl View Post
14. Yes

15. 2017 thru 2020 are all now late so I would submit them all together, which if you are doing the streamlined process you will have to do.
Got it. Are you familiar with the 'Delinquent' submission process? How does that differ to Streamlined? In both cases, you're submitting all the late forms. In the streamlined, you are submitting it with an upfront 5% penalty.

Originally Posted by Glasgow Girl View Post
16. Do them all at the same time,
Originally Posted by Glasgow Girl View Post
17. You submit your justification for being delinquent at the same time you submit all your past FBARs , 8938s and tax forms.
Thank you once again for your detailed responses. You seem to know your stuff really well. Have you personally had to deal with late FBAR/8938 submissions?
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Old Dec 18th 2021, 10:18 am
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Default Re: Huge Issues with FBAR and 8938

Originally Posted by Glasgow Girl View Post
I sympathize with you, it is a very bad situation. You are not alone, many people have fallen into this situation. Sometimes there are other options depending upon circumstances but In your case my very strong advice is to go with a professional and do the streamlined process. Bad as that is, doing anything else could put you in a MUCH worse situation. I have used Turbo Tax for many years and can assure you that for quite a few years now, certainly since 2017, it has asked if you have foreign investment or savings and it does advise that you need to complete an FBARand 8938, so it will be hard to argue you were unaware of the requirements. Plus, it is publicized everywhere, and in any case in the IRS world it is your responsibility to be aware of all tax requirements. Ignorance of the law is not a recognized defense.
I just went through my old TurboTax submission and I did not see a prompt for foreign assets reporting. Do you think that it was possibly that I purchased the wrong edition?

I understand that ignorance is no excuse. But I genuinely only found out about FBAR through a search on the internet when I was looking for information about transferring funds from overseas. It may sound lame, but that is what happened.

Separate question : If I want to consolidate funds in the US from my foreign bank accounts, do you know if I need to notify the IRS and/or fill out forms before do so, to let them know that these funds are my own and not anyone else's and are not additional sources of income?

Originally Posted by Glasgow Girl View Post
The penalties for the streamlined process are outrageous, particularly since so many people find themselves in this situation by accident. However the penalties for doing anything outside of the streamlined process can potentially wipe out all of your foreign savings and still leave you owing the IRS, so not a good road to travel.
I saw someone else's post 'Scotsman in Texas' who was in a similar situation as I, albeit a few years ago, who would have incurred a $100K penalty under the Streamlined process. Instead he submitted as Delinquent. Do you know if that is still a viable path?

Originally Posted by Glasgow Girl View Post
Dont delay in resolving this, time is not your friend in this situation.
I definitely want to act before IRS contacts me. The CPA says it will take 45 days to submit. I looked through the forms and I think I could submit them myself in less than a week. I am concerned that waiting 45 days to submit may leave me exposed for longer than I would like. Is there anyway to flag to IRS that I am now aware and taking steps to become compliant instead of waiting 45 days to submit.

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Old Dec 18th 2021, 10:21 am
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Default Re: Huge Issues with FBAR and 8938

Originally Posted by baggy1971 View Post
Glasgow Girl has given you good information. Be wise and follow what she has suggested. Above all, get professional help to resolve this - You're in a bad place and won't be able to untangle this yourself effectively.

As mentioned, Turbotax does state that you may have reporting requirements for FBAR and 8938 every time you use it (after answering the questions about having foreign accounts). You should not ignore the advice it's giving you. It's doing you a favor.

I fell foul of the FBAR reporting many years ago, but that was after it was newly introduced. There was a period of time where you could correct the matter with back dated FBAR forms and no penalty, since they had some sympathy for people not knowing it was a requirement, but that time has since expired. A well written letter of explanation may get you some relief.

Best of luck.....and as mentioned.....waste no time getting this fixed.

Thank you for the advice.

I looked over my past TurboTax and AmeriTax submissions and I couldn't find any prompt for the foreign asset/income declaration. Did I get the wrong version of TurboTax? I will search through it again to double check.


On the side : Have you experienced or heard of anyone who has been severely penalised for situations like this? Do you know what their situation was and what penalties were imposed?

Last edited by Nick12; Dec 18th 2021 at 10:24 am.
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Old Dec 18th 2021, 11:11 am
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Default Re: Huge Issues with FBAR and 8938

A Quiet/Silent/Delinquent disclosure are all different names for the same things which is submitting late FBARs and/or 8938s and/or paying foreign tax late for one or more years, without going through the official streamlined process for resolving these situations and paying the penalties. The statute of limitations on FBARs is 6 years but there is no statute of limitations on not filing Form 8939, and that means your tax return remains subject to audit for ever.

Normally, the most severe FBAR penalties of are reserved for high dollar criminals, but they will fine you if they catch you and it is almost certain that the fines will be significantly more than you would have paid under the streamlined process. Think about it, they are not going to reward you for trying to avoid any penalty. It does not matter how much tax you owe the IRS, be it $1 or more, the point is tat you failed to submit FBARs and form 8938 and in the IRS eyes you are hiding foreign accounts and that is what the penalties are designed to deter. Being ignorant of the requirement does not cut you any slack. Thousands of people been caught in the same same situation as you and for the same reason they were genuinely not aware of the requirement, that is why the streamlined process exists. The message is you will not be treated with mercy because you did not know of the requirement, you will be treated harshly for trying to avoid the process.
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Old Dec 18th 2021, 11:20 am
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Default Re: Huge Issues with FBAR and 8938

It may only take your accountant 45 days to submit the streamlined process but can take the IRS months to several years to process ad close out the case, It depends upon what is involved, their manpower and how much digging they want to do.

It is very bad to contact the IRS and “confess” without taking the proper steps to resolve the situation. You have just give them all the information they need to prosecute you. More importantly once the IRS knows you are delinquent in these matters you are no longer eligible for the streamlined process.

First Time Abatement does not apply to a failure to declare foreign accounts. You are one of thousands, if not hundreds of thousands in exactly the same situation. Many of those folks have small balances and very small amounts of unpaid tax. You are not unique at all.

If the POA is limited to submitting paperwork for the streamlined process it should be okay, so long as you trust the person you give it to, and they have appropriate qualifications to act on your behalf. Once you do that you are legally bound by whatever that person does on your behalf.
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Old Dec 18th 2021, 11:38 am
  #15  
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Default Re: Huge Issues with FBAR and 8938

It is not 100% clear if pensions need to declared on FBAR and 8938, the safest thing is to do so, but if you have a professional experienced in doing the streamlined process then they should be able to advise on that. If they are not required to be declared the IRS won't asses a penalty of those amounts. IMO better safe than sorry. Going through this process and then having the IRS find other undeclared accounts will cause you major problems.

You professional should be able to identify funds that were in two accounts. Give him the information required to prove that funds were transferred from one account to another and that should be taken into account when the penalties are calculated.

On your amended 1040 you also need to include Form 8938, I don’t know if you can submit that form online with an amended return, but in any case if you do so you are now back to attempting a quiet disclosure. All amended 1040s are manually reviewed by the IRS. Doing this will shine a very bright light on your issues.

An official statement of you maximum balance and all income ought to suffice.

The streamlined process absolves you form any further fines penalties for the years that you have declared and gives you peace of mind. A quiet disclosure leaves you exposed for ever because there is no statute of limitations on Form 8938, and if caught you should expect MUCH higher penalties. Plus, as previously stated all amended returns will be reviewed manually and you really do not want ti be caught trying to avoid the streamlined process and penalties.

The FBAR form requires that you inform the IRS that you have opened or closed accounts, and the maximum value of each account. That is how they can trace what you have been doing with your funds.

First time through, Turbo Tax will ask if you have any foreign accounts. After that if you say no, it will not go any further, nor will it ask you again.

Last edited by Glasgow Girl; Dec 18th 2021 at 11:43 am.
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