When Form 8865 Compliance 2023-2024

Music in order to force specified persons to report all of this. There is a nice set of penalties for failure to file, $10,000 if there is a if the IRS sends out a notice and within 90 days the person still does not follow the form, the penalty accumulates at about $10,000 per month. Kept at fifty thousand accuracy related penalty if under payment of tax is related to a transaction involved any of these specified foreign financial assets, the accuracy related penalties go automatically to 40 percent. Civil fraud penalty is actually similar to a regular civil for a penalty. In 75 percent, criminal penalties are possible as well, usually they're combined with something very substantial income tax non-compliance. We have not really seen yet, at least yet because remember this is a fairly new form. We have not really seen form 8938 criminal penalties being imposed, it's probably coming down the road but not yet. And then there is, there are significant implications for the statute of limitations with respect to the examinations statute of limitations. Basically, the ability of the IRS to go back and open up a tax return until you file a form 8938, the statute of limitations never starts to run. Basically, the return is open forever so the IRS can go back and impose the penalties for the form 8938 that was not filed as a 2011 tax return. And by opening out the tax return, they can find other things and other penalties may accumulate. But there's another aspect of it, the statute of limitations and the assessment of tax. So we're talking about the situation where it doesn't matter, and this is the critical core, it doesn't matter whether the form 8938 was even required to be filed. As long...