I saw this link provided by TaxMonday in another thread.
https://www.natlawreview.com/article/wh ... -financial
Thank you to TaxMonkey. I have never read an article that has discussed 'quiet disclosure' in such details.
I think the author's opinion is that 'quiet disclosure' should be considered if and only if all income has been reported and all taxes have been paid in the original filed tax return.
Now I have a prospective new client who has owned an foreign account for many years but has never reported it before. Now she wants to go with the 'quiet disclosure', amends the last 6 years of tax return and files the last 6 years of FBAR. But she also has unreported rental income (from an oversea rental property) that has to be included in the amended returns though. Because of that, I think 'quiet disclosure' should not be used.
What about if she insists on doing the 'quiet disclosure'. As the tax returns preparer, are we exposed to any liabilities by going with her wish to use 'quiet disclosure' because of her own insistence even after we have explained to her that it is not an advisable option in her case?