Hi,
My new client recently got IRS notice with penality and tax due resulting from 2021 unreported 1099 k income (the return done by the client themself). Per IRS instruction, not required but it is allowed to attach the amended return (recalculate the cost associated with the 1099k income), I can handel this part.

Further look I found they have a couple of foreign bank accounts the total amount >$10k, they never heard the FBAR request so never reported.

So I am wondering if I am able to file for 114 along with the amended return for 2021?

Or how should we handel the missing 114 forms for all the 6  years from 2022 and prior all the way back?

Any suggestions will appreciated.