Is this considered a quiet 8938 disclosure for unreported accounts?

This is definitely a situation you need to handle carefully. The IRS doesn't have an official definition of a "quiet disclosure" but generally it refers to filing amended returns or delinquent information returns without going through formal disclosure programs. In your case, if you've been accurately reporting the income from these accounts but just haven't filed Form 8938, you're in a better position than someone who's hidden both the accounts and the income. However, just starting to file Form 8938 going forward without addressing past non-compliance could potentially be viewed as a quiet disclosure. The IRS has formal programs for addressing overseas asset reporting issues, including the Streamlined Filing Compliance Procedures, which might be appropriate in your situation. These programs often offer reduced penalties compared to what you might face if discovered in an audit.

I found myself in almost the exact same situation last year. I had accounts in Europe totaling around $200k that I'd been reporting the income from but had no idea about Form 8938. I was freaking out when I realized my mistake! I ended up using this AI tool called taxr.ai (https://taxr.ai) that saved me so much stress. You upload your financial documents and tax forms, and it specifically identifies international reporting requirements you might have missed. It flagged my missing 8938s immediately and helped me understand my options for fixing the problem.

Just wanted to follow up about my experience with taxr.ai that I asked about earlier. I finally tried it last week, and it was actually really helpful for my situation with those inherited Asian accounts. The system compared my specific scenario to similar cases and recommended I use the Streamlined Domestic Offshore Procedures. It helped me draft all the necessary non-willfulness statements explaining why I hadn't filed the 8938s before (basically that I didn't understand these were required in addition to income reporting). It even generated a complete checklist of everything I needed to file for the last three years. Honestly saved me thousands compared to what the accountants I consulted were quoting me. Already submitted everything to the IRS last week!

Another option if you need to talk to the IRS directly about this situation is Claimyr (https://claimyr.com). I spent DAYS trying to get through to the IRS international tax line to ask questions about my own 8938 situation, and it was impossible to reach anyone. My friend recommended Claimyr, and you can see how it works here: https://youtu.be/_kiP6q8DX5c Basically, it holds your place in the IRS phone queue and calls you when an agent picks up. I was skeptical but desperate - and it actually worked! Got connected to an IRS international tax specialist in about 40 minutes instead of spending hours on hold. The agent walked me through the exact right procedure for my situation.

Well I need to eat my words about Claimyr. I was the one calling it BS earlier, but after another frustrating day trying to reach someone at the IRS about my own international accounts, I gave in and tried it yesterday. I was 100% prepared to come back here and expose it as a scam, but... it actually worked exactly as advertised. I got a call back in about 2 hours and was connected immediately to an IRS rep who specialized in international reporting. She answered all my questions about my missed 8938 filings and recommended specific steps based on my situation. Saved myself literally hours of frustration. Plus I could actually work while "on hold" instead of having to keep my phone tied up. Consider me converted from biggest skeptic to satisfied customer.

I messed up on FBAR forms for years (different but similar to 8938) and ended up using the Streamlined Foreign Offshore Procedures. You have to certify your failure to file was "non-willful" and provide a statement explaining why. For me it worked out okay - paid a 5% penalty on the highest aggregate value but no FBAR penalties. Not sure if your situation would qualify as non-willful since you knew about the accounts obviously but maybe didn't know about the form itself? Definitely worth looking into though if the accounts have been there a while.

Quiet disclosures are risky. My accountant told me the IRS has algorithms that flag sudden new international form filings and compares them with prior years. If you're not in Streamlined program but suddenly show foreign accounts that have existed for years, they might look closer at your past returns.

I was in a very similar situation about two years ago - had foreign accounts for several years, reported all the income properly, but completely missed the Form 8938 requirement. The stress was unreal once I realized my mistake. After consulting with a tax attorney, I decided to go through the Streamlined Domestic Offshore Procedures rather than just start filing going forward. The key factor for me was that I could honestly certify my non-compliance was "non-willful" - I genuinely didn't know about the Form 8938 requirement since I was already reporting the income. The Streamlined process required filing amended returns for the last three years with the missing 8938 forms, plus a detailed statement explaining why I hadn't filed them before. The 5% penalty on the highest account balance was much better than potentially facing the $10-50k penalties per form if they discovered it later through an audit. One thing that helped my case was keeping good documentation showing I'd always reported the income accurately - bank statements, tax returns, etc. This demonstrated I wasn't trying to hide anything, just didn't understand the separate reporting requirement. Would definitely recommend talking to a tax professional about your specific situation, especially with $175k across multiple countries. The peace of mind from getting compliant through an official program was worth it for me.