For years, one of my oldest friends has been delinquent with his returns. He lives in Europe and travels constantly. I finally got him caught up, and now he is finally going to file his first and timely TDF 90-22.1. He has not filed all his many past-year Reports of Foreign Bank Accounts, going back to 2002.

I am trying to obtain information for him as to what might be the best course of action. I believe the penalties are horrendous--20% of the total value of accounts. And would that be for each year?? I believe that the penalty can be waived, for reasonable cause, but that's obviously a gamble. What would you recommend? That he just file the 2008 and be timely hereafter? Many thanks!!!

Michael Rothschild, EA, MFA California