A quiet disclosure is filing amended or late returns and FBARs that report previously omitted foreign income or accounts without using an IRS disclosure program, in the hope they are processed without scrutiny.
The IRS has said it will not treat quiet disclosures as satisfying its programs and may examine them. In willful cases, the filings themselves can become evidence. The formal alternatives are the streamlined procedures and the Voluntary Disclosure Practice.
Why it matters: a quiet disclosure gives up the penalty protection of a program without removing the exposure.
Read more: why quiet disclosures are risky.
FBAR, FATCA, streamlined procedures, voluntary disclosure, and foreign trust and gift reporting.
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Definitions are general information, not legal advice, and may not reflect the most recent changes in law.
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