Taxpayers who do not need to use either the OVDP or the Streamlined Filing Compliance Procedures to file delinquent or amended tax returns to report and pay additional tax, but who:
have not filed a required Report of Foreign Bank and Financial Accounts (FBAR) (FinCEN Form 114, previously Form TD F 90-22.1),
are not under a civil examination or a criminal investigation by the IRS, and
have not already been contacted by the IRS about the delinquent FBARs should file the delinquent FBARs according to the FBAR instructions.
The general steps to participate in the program include:
Include […]
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