Client omitted foreign account income and FBAR

Technical topics regarding tax preparation.
#1
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Hi all - my client's spouse had a foreign account, he thought it was her mom's account, but it's in spouse's name. He's a line-by-line return checker, and didn't remark on my marking Sch B boxes "no" all these years.

There's been 10K-20K US equivalent in this account for ... maybe 10 years? He contacted a tax attorney who said the solution is "nonwillful statement", filing six years of FBARs, and amending open years to report interest income (~500/yr max).

The tax attorney quoted something like 10K to prepare the statement.

I am not advising him on this in any way, but will amend the returns.

Questions:
Does the catch-up filing sound correct?
Is the nonwillful statement something he can DIY? He's willing to pay the cost, but seems egregious for accidental noncompliance for such a minimal amount to be such a big event.

Thanks for any thoughts!
 

#2
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#3
HowardS  
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The last time I did this I filed the delinquent FBARs with the statement and 6 years prior returns with payments for each year as separate checks for the unreported interest. The checks were returned for the 3 out of SOL years. I guessed those checks would be returned but I wanted to show an attempt at compliance. Never received any FBAR penalties.
Retired, no salvage value.
 

#4
Guya  
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This sounds a typical SDOP fact pattern. Have you done much SDOP work? The outcome will be 3 years amended plus 6 FBARs and a Misc 5% penalty along with IRS Form 14654. The attorney also gave incorrect advice incidentally.
PS – Greeting from London, England. Grey and rainy ...
 

#5
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Thanks all. I've not done SDOP work (don't even recognize the term). Will pass this info along to him.
 

#6
Guya  
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It may help to mention that we handle SDOP cases every day. Glad to help if needed.
PS – Greeting from London, England. Grey and rainy ...
 


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