Glossary · Reporting
Delinquent FBAR Submission Procedures
An IRS route for taxpayers who filed their US returns and reported their income correctly but missed the FBAR. The overdue FBARs are e-filed with a reason for the delay, and — where the related income was properly reported — generally without penalty.
In more detail
The Delinquent FBAR Submission Procedures address a narrow situation: US returns filed, income correctly reported, but the FBAR (FinCEN Form 114) not filed. The overdue reports are submitted through the BSA E-Filing System with a stated reason for filing late. The IRS has indicated it will not impose a penalty for a delinquent FBAR where the income from the accounts was properly reported and tax paid. It is narrower than the Streamlined Filing Compliance Procedures, which also correct the underlying returns; where income was under-reported, this route is generally not available.
Does Delinquent FBAR Submission Procedures apply to your situation?
Cross-border tax turns on the detail of your circumstances. Book a consultation and we'll tell you exactly where you stand.