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What are the risks of an IRS quiet disclosure? Is there a formal IRS process known as a "quiet disclosure," and does the IRS honor this strategy for amended tax returns?...more
On Feb. 28, the U.S. Supreme Court ruled that non-willful penalties related to FBARs apply to each report filed, not on a per-account basis. The 5-4 decision resolved a split between the Fifth and Ninth circuits that focused...more