IRS Taxpayer Advocate to IRS: Stop Scaring Those Who Inadvertently Fail to File FBARS
January 18, 2012 at 10:22 AM
In her annual report to Congress released last week, IRS Taxpayer Advocate Nina Olson criticized the IRS on issues related to the administration of FBAR matters, including the IRS's repeated references to maximum penalties provided by law when, under the IRS's own existing guidelines, many taxpayers would not be subject to penalties. The Report called for the IRS to issue a notice or similar annoucment:
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Describing, reaffirming, and expanding the taxpayer-favorable procedures provided in the Internal Revenue Manual; and
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Telling people what to do if they discover they have inadvertently failed to file FBARs, and reassuring them that they are most likely to receive a warning letter in accordance with the IRM if they follow the instructions provided by the notice.
The Taxpayer Advocate's report is much appreciated by those who counsel U.S. persons on FBAR issues.
The attorneys of the Pittsburgh tax law firm Williams Coulson have successfully advised many clients on FBAR matters and are available to discuss any issues you may have.