Tax professionals, the IRS, and FinCEN have independently and together worked to find ways of bringing taxpayers back into compliance through the IRS Voluntary Disclosure program. Currently there are many ways to come clean with the IRS and FinCEN. Each method will be discussed in detail later. This section will provide an overview. A method previously advised by accountants is doing nothing and hope for the best. With the growing number of countries and foreign financial institutions becoming complainant under FATCA, this no longer is a sensible option. If you hold a non-disclosed offshore account, it will eventually be discovered. Now is the time to act. To decide what option is best for your situation, you should retain legal counsel whose practice concentrates in taxation. Your conversations with your accountant are not protected by attorney/client privilege. You should engage legal counsel to assist you in deciding what the best course of action is.
 “What to do When a Client has an Undisclosed Foreign Account” Novak, Scott. Journal of Accountancy (December 2013)
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