Taking on Clients - Streamlined Filing

I had two potential clients. Both are US citizens.

Client A has been filing all US returns but just discovered that she had a foreign account opened by her parens living overseas on her behalf. The account is under her name. She has the obligations to file. So she has not filed FBAR for a couple of years.

Client B used to live in US but they moved overseas for 20 years and have not filed any US returns since then. Now they want to file.

None of them have contacted by the IRS.

I have enough experience in preparing Expat returns but not in Streamlined filing procedures. Should I take on these jobs? Or should I send them to a tax attorney? I have read on different discussions on the forum.

These are high stakes issues with huge potential penalties. If you are unsure, kick the work upstream.

The penalties can be very large. Sometimes reasonable cause is a defense. Clients needs to be advised of their options, and the best and worst case scenario for each option. Don't guarantee anything or imply certainty. If you don't know enough about the VDP and SDOP/SFOP, or aren't willing to put in the hours, you should punt.