Hello, and welcome to Sherayzen Law Office video Blog. My name is Eugene Sherayzen and I’m an international tax attorney and owner of Sherayzen Law Office, Ltd.
I’m continuing a series of blogs from Beverly Hills, California. Today, I’d like to discuss the FBARs that must be submitted as part of an SDOP disclosure. Now, this is actually pretty normal because the IRS Statute of Limitations is six years, so it is logical that the IRS would require you to submit correct FBARs for the period that encompasses the entire Statue of Limitations for the FBAR.
What is important to emphasize though, is when FBARs are submitted as part of the Streamlined Domestic Offshore Procedures, they have to expressly state so. In other words, FBARs must state, (there’s a special option ‘other’ which you can chose when you file the FBAR) in that section: “This FBAR is filed pursuant to Streamlined Domestic Offshore Procedures”. Again, to repeat myself, the explanation for each FBAR e-filed as part of the SDOP disclosure, must expressly state: “This FBAR is filed pursuant to Streamlined Domestic Offshore Procedures”.
Additionally, and this is completely voluntary, but I believe is useful, that it is a good idea to state the most important non-willfulness arguments in the same explanation, when you file your FBARs.
Thank you for watching, until the next time.