In some cases, legal counsel is not necessary to correct a minor mistake on a previously filed Form 547
However, filing a late Form 547
A U.S. person with an unreported account at a Swiss financial institution or in a jurisdiction which the U.S. government considers a tax haven, or who maintained an account at a foreign financial institution currently under investigation for assisting U.S. taxpayers with evading tax, should immediately consult with legal counsel.
The attorney-client privilege provides a critically important protection allowing any analysis of whether the person’s conduct may be viewed by the government as willful or criminal to remain protected from disclosure to the IRS. Communications with accountants or non-lawyer tax professionals are not covered by any attorney-client or similar privilege.
No correction options are available to a U.S. person who is already under IRS audit or whose noncompliance has already been identified by the government. Thus, time is of the essence to correct Form 547