We are preparing 2020 return ...She is US citizen but since May 2018, she is living in India.
She has bank account (foreign asset) in USA since May 2017 and in 2020 tax year she had peak foreign assets worth about 1.75 lac .
She did not file tax return in 2017 or 2018 or 2019 because her total income was less than exemption amount.
But recently I found that even if her taxable income was less than threshold - just because she had foreign bank account - she had to file income tax return during those years but we did not.
Now this year when she is preparing return - she has to submit FA sch - and in that it ask when was this account opened...now if we mention actual date of May 2017 - - do we have to pay penalty for not filing tax return in last 3 years ? if yes what is the penalty amount per year?
Also can we just mention account opening date as of Jan 2020 -? she did not have any income those years ..she only had bank account in which she has less than 75k i.e. $1000 that was also gifted by her son.