Serbinski Accounting Firms

Since the company consists of cash, wouldn't it be a PFIC and therefore it cannot pay qualified dividends

it is definitely OVDI. Its using the letter, and its being filed before the Sept 9 deadline.

The way the attorney sees it is that many of the IRS agents are lazy, they have so many of these OVDI cases, it may get just thrown out because somebody looks at it and decides it doesn't belong in OVDI ...

I heard back from my US tax attorney earlier this week.
We are filing 8 years of 1040, all zero balance, nothing owing on the small amount of investment income from Canada. They have prepared the OVDI letter, its actually quite simple as most of the stuff is non applicable or common sense type stuff ...

Does anybody have any evidence in the way of emails from IRS where they state answers to questions. ie: no penalty for quiet disclosures if you do not owe US taxes. Or whether you can use FAQ 17 to file FBAR and prior years returns at the same time. I find the FAQ are basically useless because they ...