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Prior Year Foreign filing: 14653 filing vs standard?

Kpeabody
Level 2

Back in 2021 during tax season, one of my clients notified me he got married in 2020. His Spouse was from Malaysia (which the US doesn't have a treaty with). She only had 2 accounts a Checking and ETF account (which would be taxable as no US treaty). Accounts are under 8938 threshold. 

She moved to the US in August 2007 under a visa and has reminded here since under a visa and then eventually a green card. 

She wasn't aware of FBAR/foreign filing and hasn't filed anything for this to date. She has filed her tax returns when required but didn't include her foreign income from her ETF (which is around1-2Kish) After explaining the tax problem she engaged me to take care of this. Seemed like a straight forward 14653. I request prior 6 FBAR info for 2013 to 2019 and 2017 - 2018 Tax Returns with the attention to amend along with 2019.

While she begins to take care of compiling the information I file her 2020 tax return with FBARs. 

The Malaysia bank give her a lot of trouble providing the prior year info. Long story short she isn't able to get it unless she physical goes there. As it was during covid this is difficult for her. She finally able to go recently by which time 2021 and 2022 have also be filed.

Here is my dilemma. With the 3 most recent tax return filed correctly I am wondering if going with the 14653 is the best choice. Is there any problem with just filing the prior year FBARS? (Marking amount unknown for the period where it isn't known) I would have to go back to 2008 (doesn't pass the physical presence test for 2007). Suppose there might be an issue if she didn't file at all in a prior year since the unearned ETF income would most likely trigger this? Would also need to keep an eye open for 8938 in case she passes it in one year? Am I missing something anything else?

If I did go the 14653 route would I still file the 2013 to 2019 and amend 2017 to 2019 since 2020 to 2022 are correct? 

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