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Characteristics of FBAR voluntary disclosures

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Characteristics of FBAR voluntary disclosures

Regardless of the underlying reasons for the establishment of the foreign account, most of FBAR voluntary disclosures made to date have a number of common characteristics:

  1. A failure to report income earned on the foreign accounts.
  2. A failure to disclose the existence of the foreign account on the individual’s U.S. tax return – there is a place to check a box answering the question whether the taxpayer has signature authority or a financial interest in a foreign account, and if so, to list the names of the countries where the account is held.
  3. A failure to file annual FBAR forms disclosing he existence of the foreign account.
  4. Potentially, a failure to file additional IRS forms regarding a taxpayer’s relationship to a foreign trust or foreign corporation, or the taxpayer’s receipt of funds from foreign sources, including gifts and bequests.

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