Is this considered a quiet 8938 disclosure for foreign assets?

This is a situation you should approach carefully. Form 8938 (Statement of Specified Foreign Financial Assets) reporting is separate from FBAR requirements, though there's some overlap. When you suddenly start reporting previously undisclosed foreign assets, yes, the IRS might notice the change. However, they don't automatically assume malicious intent. The question is whether this constitutes a "quiet disclosure" - which is essentially correcting previous non-compliance without formally entering an amnesty program. The IRS generally prefers taxpayers to use official disclosure programs for past non-compliance rather than quiet disclosures. The Streamlined Filing Compliance Procedures might be appropriate for your situation if you can certify your failure to file was non-willful. If the non-disclosure was truly unintentional and you want maximum protection, consider discussing the Streamlined procedures with a tax professional who specializes in international tax compliance. This gives you formal protection rather than hoping the IRS doesn't notice or care about the sudden appearance of foreign assets.

I went through the same stress when I realized I had overseas assets that needed reporting. Tried different accountants and got conflicting advice until I found this AI tool called taxr.ai (https://taxr.ai) that really cleared things up for my foreign asset reporting situation. I uploaded my financial documents, and it helped identify exactly which accounts needed Form 8938 reporting versus FBAR requirements. The system flagged potential compliance issues with my previous non-reporting and gave me clear guidance on whether the Streamlined Filing program was appropriate in my case. Saved me from making a costly mistake since my previous accountant was just going to "fix it going forward" too without addressing the past non-compliance.

I wanted to follow up about my experience with taxr.ai after being skeptical. I ended up trying it for my own foreign account situation and was honestly surprised. The analysis showed me that my situation actually qualified for a specific exemption I didn't know about (foreign pension accounts that fall under certain treaty provisions). It highlighted the exact sections of the tax code and provided me with the proper form references and reporting requirements. What was most helpful was getting a clear explanation of my risk exposure with different approaches - turns out in my case, a quiet disclosure would've been particularly risky due to some specific factors in my filing history. Saved me from what could have been a serious compliance mistake.

If you need to actually speak with someone at the IRS about this international reporting situation (which might be smart before deciding your approach), good luck getting through on your own. After waiting on hold for 3+ hours multiple times trying to get guidance, I found a service called Claimyr (https://claimyr.com) that actually got the IRS to call ME back. You can see how it works in this video: https://youtu.be/_kiP6q8DX5c - but basically they hold your place in line and when they reach an agent, they connect you. I was able to speak with someone in the international tax department who gave me official guidance about my specific disclosure situation without revealing my identity. Helped me decide between quiet disclosure vs. streamlined filing with actual IRS input.

I have to eat my words about Claimyr. After posting that skeptical comment, I decided to try it myself because I was desperate to talk to someone about my foreign account situation. Within 45 minutes of using the service, I was talking to an actual IRS agent in the international department. I asked hypothetically about the difference between just starting to file correctly versus using the formal disclosure programs. The agent explained that while they can't make recommendations for specific cases, sudden reporting of significant foreign assets after years of non-reporting often gets flagged for review. They said the formal programs provide certain protections that "quiet" compliance doesn't. This was exactly the confirmation I needed to decide on using the Streamlined program rather than risking a quiet disclosure. Completely worth it.

Just wanted to add my experience - I had unreported foreign assets for about 4 years (around $200k) and decided to just file correctly going forward without amending or doing streamlined filing. That was 3 years ago and nothing has happened. No audit, no questions. I think the IRS has bigger fish to fry than people who make honest mistakes and correct them going forward. Not saying that's the right approach for everyone, but wanted to share a positive outcome.

Anyone know if the IRS can actually see when you started having these foreign accounts? Like if I've had them for 10 years but only started reporting them now, can they tell the accounts have existed for a decade? This quiet disclosure question is keeping me up at night!

I'm dealing with a similar foreign asset reporting situation and wanted to share what I learned after consulting with an international tax attorney. The key distinction here is that Form 8938 and FBAR serve different purposes - 8938 is part of your tax return while FBAR is filed separately with FinCEN. The "quiet disclosure" concern is real. When you suddenly report foreign assets that weren't previously disclosed, it can trigger questions about why they weren't reported before. The IRS has sophisticated matching systems that can identify patterns like this. For your $275k in assets, you're definitely above the reporting thresholds. My attorney explained that while some people do get away with quiet disclosures, the formal Streamlined Filing procedures provide legal protection and closure. The penalty (5% for domestic taxpayers) might seem steep, but it's often much less than the potential penalties for continued non-compliance if discovered later. The fact that your accountant "shrugged it off" is concerning - this is exactly the kind of situation where specialized expertise matters. I'd strongly recommend getting a second opinion from someone who specifically handles international tax compliance before deciding your approach.

I've been through this exact situation with foreign assets around the same value range. The stress is real, but let me share what worked for me after making the same mistake. First, your accountant's casual approach is a red flag. International tax compliance isn't something to "shrug off." I initially tried the quiet disclosure route too - just started filing Form 8938 correctly going forward without addressing prior years. But the anxiety was killing me, especially after learning that FATCA reporting means the IRS likely already has visibility into many foreign accounts. I ended up using the Streamlined Domestic Offshore Procedures about 6 months after my initial "quiet" filing. Yes, there's a 5% penalty on the highest aggregate balance, but here's what sold me on it: legal certainty. Once you complete the streamlined filing and pay the penalty, you get formal closure. No more sleepless nights wondering if the IRS will come knocking. The process took about 4 months from submission to receiving my closing letter. During that time, I felt much more secure knowing I was in an official compliance program rather than hoping my quiet disclosure wouldn't be noticed. Given your asset level ($275k), the streamlined penalty would be around $13,750 - painful but manageable compared to the potential penalties and legal costs if things go sideways later. My advice: bite the bullet and get the peace of mind. The stress relief alone was worth it for me.