If you have foreign bank accounts, you're required to file an FBAR (Foreign Bank Account Report) when the total value of all your foreign accounts exceeds $10,000 at any time during the calendar year. This includes accounts in any country, whether it's Canada, the UK, India, China, or anywhere else. The FBAR is filed separately from your tax return through FinCEN (Financial Crimes Enforcement Network). Missing this deadline or filing incorrectly can trigger penalties ranging from $10,000 to $100,000 per violation—or even higher for willful violations.
The FBAR filing deadline aligns with your tax return deadline (April 15, with automatic extension to October 15). You must file electronically through the BSA e-filing system. You're required to report all accounts where you have signature authority, even if the account belongs to your employer or a government entity. Our Livonia tax attorneys help you understand your filing obligations and correct past non-compliance before penalties escalate.
We provide comprehensive FBAR compliance solutions for Livonia residents:
Streamlined Filing Compliance Procedures: For taxpayers with non-willful FBAR violations, the IRS offers streamlined procedures that allow you to catch up on unfiled FBARs with reduced penalties.
Delinquent FBAR Submission Procedures: If you didn't file FBARs but properly reported all income from those accounts on your tax returns, you may qualify for delinquent FBAR submissions with no penalties. We prepare your late filings and handle all IRS correspondence.
Reasonable Cause Statements: We craft compelling explanations for late filing, whether due to reliance on incorrect professional advice, medical emergencies, natural disasters, or other circumstances that the IRS may recognize as reasonable cause.
Voluntary Disclosure Program: For situations involving willful non-compliance or potential criminal exposure, the IRS Voluntary Disclosure Program allows you to come forward before the IRS finds you. We guide you through this process to minimize criminal prosecution risk and reduce civil penalties.
The IRS imposes harsh penalties for FBAR violations:
Non-Willful Violations:
Willful Violations:
Increased IRS Scrutiny:
Our FBAR attorneys help clients correct past non-compliance through voluntary disclosure programs, reasonable cause statements, and streamlined filing procedures—often reducing or eliminating penalties entirely.
Our tax attorneys have helped clients reduce FBAR penalties by millions of dollars through streamlined procedures, reasonable cause arguments, and successful IRS negotiations. We understand how FBAR requirements intersect with tax treaties, FATCA, Form 8938, and foreign income reporting.
Our experience includes everything from simple single-account FBARs to complex cases involving multiple foreign financial institutions, offshore mutual funds, foreign pension plans, and international business accounts.
Minor FBAR filing issues can escalate into penalties exceeding $100,000 and IRS criminal investigations. The IRS has increasingly aggressive enforcement programs targeting unreported foreign accounts, and waiting only increases your penalty exposure.
Get experienced legal guidance for your foreign account reporting:
Contact our Livonia FBAR attorneys at (248) 262-3400 for a free case review.
