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The FBAR deadline is April 15 of the following year, and FinCEN grants an FBAR automatic extension to October 15, with no request needed. A filer who misses both dates through mistake or oversight can face a civil penalty of up to $16,536, the non-willful cap for penalties assessed from January 17, 2025.
A US citizen, resident or domestic entity must report foreign financial accounts, including foreign bank or brokerage accounts, when their highest balances for the year, added together, exceed $10,000. Signing authority counts too. The report is FinCEN Form 114, the Report of Foreign Bank and Financial Accounts (FBAR). Our CPAs and enrolled agents (EAs) prepare and e-file it.
You report a closed foreign account on the FBAR for the year it closed, at its highest value during that year. We still report that peak when the account closes at zero.
Treasury requires each FBAR filer to keep a record of every account's maximum value for five years. We ask clients to download the year's statements before closing an account, while they can still log in.
We handle FBAR filing for closed accounts from the final statement, or from bank letters and transfer records when a statement is gone.
A client closes a foreign savings account in March and expects to leave it off the report.
Illustrative figures in US dollars: savings account peak $7,200 before the March closing, brokerage account peak $4,100 in September.
We add the two peaks to get $11,300, above $10,000, so we report both accounts on that year's FBAR.
A filer who leaves the closed account off files an incomplete FBAR and needs an amendment.
If you have a tax question, whatever the least appealing answer would be, that's probably the right answer.
You upload each account's statements for the year to our encrypted portal.
We take each account's peak and convert it at the Treasury year-end rate.
You sign FinCEN Form 114a so we can e-file, and we keep it on file as FinCEN instructs.
We e-file through BSA E-Filing before the FBAR filing deadline and send its BSA Identifier.
Yes. For any year past its FBAR deadline, we prepare a late FBAR filing through BSA E-Filing and enter the reason for the delay on page one.
Under the IRS manual, examiners assert no penalty when the filer did not act willfully and had reasonable cause. The filer also has to report the account correctly on the late FBAR.
The IRS no longer lists a separate procedure for late FBARs among its offshore compliance options, so we write a reasonable cause statement for each late filing.
A client who also left the account income off the tax return needs more than a late FBAR. We move that case to a streamlined offshore procedures review, where we prepare amended returns and the missing FBARs together.
From FBAR deadline to late filing
One report per calendar year, filed through BSA E-Filing
Combined peak value of foreign accounts above $10,000 on any day. Accounts closed during the year count.
THE TESTFor the calendar year just ended.
ON TIMENo request needed.
STILL ON TIMEWe pick the route from one question.
LATEIRS examiners assert no penalty when the filer did not act willfully, had reasonable cause and reported the account correctly.
Yes income reported, tax paidAmended returns and the missing FBARs, prepared together.
No income left off the returnSend the years in question and whatever statements you still have. A CPA reviews the missed years before anything is filed.
We file an FBAR amendment when an account is missing from a filed report or its maximum value is wrong. We prepare the full corrected report and mark it as an amendment.
We link the corrected report to the original BSA Identifier, so FinCEN matches the two.
We price each foreign account on each year's report, late years included.
If you also meet the Form 8938 threshold, we prepare both and file each separately.
When we also prepare the individual tax return, we use one set of statements.
The lightest file is one account, one year, with statements in hand. These are the factors, not a quote.
Returns e-filed in 2024
Maximum email reply time
Days a year of client support
Source: Dimov Tax internal records.
Speedy, friendly service with a more complex return with corporate stocks and bonuses in foreign currencies.
Send the account list and the years in question, and we quote a fixed fee before anything is filed.
