The federal government has broad investigative powers into the financial assets of Americans—even those accounts held overseas. The IRS taxes American citizens and residents on the income related to their financial accounts worldwide and the federal government relies on taxpayers to disclose these accounts as part of the process.

One of the documents used in this process is referred to as a Report of Foreign Bank and Financial Accounts (FBAR). The law requires that you file an FBAR along with your tax returns under certain circumstances. If you have failed to file your disclosure or are unsure if these rules apply to you, a Vienna FBAR lawyer might be able to help. A seasoned tax attorney could help you work out compliance issues or address filing delinquencies.

What is an FBAR?

FBAR requirements are fairly straightforward. These disclosures are mandatory for a “United States person” with overseas accounts that hold more than $10,000. For these purposes, a United States person is an American citizen, an American business, or a lawful permanent resident.

The process of filing an FBAR statement is done online. Any United States taxpayer that meets the threshold requirement must file an FBAR statement annually through the Financial Crimes Enforcement Network (FinCEN) using the U.S. Department of the Treasury website.

The deadline for filing this disclosure falls on April 15 each year and it applies to financial accounts that were open at any point in the entire previous calendar year. FinCEN will grant an automatic extension until October 15 with no extension request needed.

The Process for Delinquent FBAR Filing

As of July 1, 2026, the IRS has removed its Delinquent FBAR Submission Procedures webpage from its website. This suggests that the administrative option for coming into FBAR filing compliance without penalties is no longer available.

The removal of these procedures does not mean that penalties will automatically be imposed for late filed FBARs. Rather, it means that taxpayers who file delinquent FBARs may now have potential penalty exposure, depending on the facts and circumstances of their case.

If you need to come into FBAR compliance, contact us to evaluate your options. We can help assess your circumstances and determine whether you may have reasonable cause to request penalty abatement if penalties are proposed or assessed.

Discuss Your Options with a Vienna FBAR Attorney Today

If you have foreign financial accounts that exceed $10,000, you are required to comply with the FBAR filing requirements. If you are not in FBAR compliance, your Vienna FBAR lawyer could also help you carefully address these deficiencies and avoid an IRS investigation. Reach out today to learn more.