Is a 'quiet disclosure' safer than Streamlined — just amend and pay without the paperwork?
Someone told me I could just quietly file the amended returns and late FBARs and pay what I owe, without doing the whole Streamlined certification. That sounds simpler. Is a quiet disclosure actually safer or cheaper than Streamlined?
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After Bittner, is the non-willful FBAR penalty per account or per year?
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I got an IRS penalty notice on my LLC — is it a CP15 or a CP215, and how do I respond?
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I missed FBARs for several years — do I use the Delinquent FBAR procedures or Streamlined?
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My U.S. controller can move money from our foreign account but does not own it. Is that the kind of FBAR issue people miss?
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Form 8275 or Form 8275-R — which one do I file to disclose a tax position on my foreign-owned LLC return?
My CPA wants to take a position on my U.S. LLC's pro forma 1120 that he says goes against a Treasury regulation. He mentioned filing either Form 8275 or Form 8275-R but I don't really understand which...
Form 843 asks for the code section behind the penalty and I am not sure what to put there. Is that a small detail or a big one?
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How do the $25,000 + $25,000-per-30-day section 6038A penalties for failing to keep records actually work?
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Should I dispute the penalty by letter now, or pay first and use Form 843 later?
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