Overview
What 'delinquent FBAR' actually means
An FBAR (FinCEN Form 114) reports your foreign financial accounts. If you were required to file one in a past year and did not, that FBAR is delinquent. Where your income was reported and tax paid, the IRS provides a usually penalty-free way to catch up.
This guide is for you if
- You reported your income but forgot or did not know to file FBARs
- You have foreign accounts that exceeded the reporting threshold
- You want to become compliant before the IRS contacts you
The process
Filing delinquent FBARs step by step
1. Confirm you qualify
You must have reported the income and paid any tax due, and not be under IRS examination.
2. Identify the years
Determine each year an FBAR was required based on your account balances.
3. Prepare a reasonable-cause statement
Explain clearly and honestly why the FBARs were late.
4. E-file through FinCEN
Submit the late FBARs electronically with the explanation attached.
At a glance
- Form
- FinCEN Form 114 (FBAR)
- Filed with
- FinCEN (electronically)
- Typical outcome
- No penalty if income was reported
- If income unreported
- Use Streamlined Filing instead
Frequently asked questions
An IRS pathway for taxpayers who did not file required FBARs but correctly reported and paid tax on the related income. Late FBARs are e-filed with a statement explaining the lateness, generally without penalty.
Then the Delinquent FBAR route usually does not apply. The Streamlined Filing Compliance Procedures are typically the correct path for non-willful cases with unreported income.
The FBAR look-back period differs from the tax-return look-back. Confirm the exact number of years for your situation with a professional.
Need help catching up?
We handle delinquent-FBAR submissions for Americans in the UK end to end.