What is the Delinquent FBAR Submission Procedure and when can I use it?
If you missed filing FBARs but reported and paid tax on all the related income, the IRS offers the Delinquent FBAR Submission Procedures. You e-file the late FBARs through the FinCEN BSA system and attach a short statement explaining why they are late. As long as you were not under IRS examination and had no unreported income tied to those accounts, the IRS states it will not impose a penalty for the late filing. This is simpler than the Streamlined program, which is designed for people who also underreported income. If you owe back taxes on foreign income too, Delinquent FBAR alone is not enough, and you should look at Streamlined Filing Compliance instead. See the offshore compliance options page on irs.gov, and consider a cross-border tax professional for anything ambiguous.
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