You have money in an account overseas. Maybe you opened it years ago, inherited it, or never imagined the IRS needed to hear about it. Now those foreign account problems need an FBAR attorney who knows how the IRS reads a foreign account file, backed by a team that used to work inside the agency.
At MD Sullivan Tax Group, tax attorneys, CPAs, enrolled agents, and former IRS agents tell you where you stand, what the IRS is likely to see, and how to come forward in a way that protects you.
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A Missed FBAR Can Cost More Than the Account Itself
The FBAR is a yearly report of your foreign financial accounts. You owe one when the combined balance of those accounts goes above $10,000 at any point in the year. Skip it, and the penalty depends on one question: was it willful?
A willful FBAR violation penalty can reach 50% of the account balance for each year, and it can be applied to several years and several accounts at once.
In the most serious cases, FBAR criminal penalties can include up to five years in prison and fines of up to $250,000. Prosecutors usually go after active concealment, large amounts, or lying to agents.
But the risk is real enough to shape how your case should be handled from day one, and that is why early strategy from an FBAR attorney matters so much.
Heading: Never Filed an FBAR? Do Not Guess. Get Protected.Body: An honest mistake and a deliberate one lead to very different roads, and the wrong road gets expensive fast. Our FBAR attorney team, backed by former IRS agents, keeps your conversations privileged. CTA Liner: Let’s Help You Come Forward Safely |
Two Paths Out. Picking the Wrong One Is the Real Danger
Most people with an unreported foreign account end up on one of two roads. Which one is yours depends on what you knew, what you did, and when.
| Factors | Non-Willful Cases | Willful Cases |
| Usual route | Streamlined Procedures | IRS Criminal Investigation Voluntary Disclosure Practice |
| Penalty level | Low or none | Higher |
| Criminal protection | Not what it is built for | IRS generally does not recommend prosecution |
| Biggest trap | Signing a false non-willful certification | Waiting until the IRS contacts you first |
How We Help You, Step by Step
Every foreign account case has its own facts, but our work usually moves like this.
1. We Put a Privilege Shield Around You
Your first conversation is with an attorney, and it is protected. When numbers need crunching, we bring accountants in under a Kovel arrangement, a setup that keeps their work under attorney-client privilege. You can speak freely, including about the parts you like least.
2. We Rebuild the Money Trail
We track every account, every year, every balance and every dollar of unreported income. Often the real picture is smaller than you fear. Sometimes it is bigger, and you are better off hearing that from us than from the IRS.
3. We Read Your Case the Way an IRS Agent Would
Willful or non-willful is the question everything hangs on. Our former IRS agents know which facts examiners grab first, such as a “no” on the foreign account question on Schedule B, money moved to avoid detection, or an accountant’s advice that was ignored. We assess your case honestly before you commit to anything.
4. We Choose the Door With You
Streamlined, voluntary disclosure, or a delinquent filing: the right route depends on your facts, not on what looks cheapest. A foreign bank account tax attorney on our team walks you through each tradeoff, so the decision is yours, and you make it informed.
5. We Move Before the IRS Does
If your case calls for an offshore voluntary disclosure, we request preclearance on Form 14457 before the IRS contacts you, then prepare the returns and reports that go with it.
6. We Take the IRS Off Your Phone
Every letter, call, and negotiation goes through us. You do not talk to the IRS. We work to keep your penalties as low as the law allows, and we see the case through to the finish.
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Signs You Should Call Us Before You Do Anything Else
If any of these situations sound familiar, talk to an FBAR lawyer before you file, amend, or answer anyone.
- You left a foreign account off your return, or answered “no” to the foreign account question on Schedule B
- You moved money abroad, or between accounts, to keep it out of sight
- A banker, accountant or relative warned you about the FBAR and you let it slide
- You received an IRS letter about foreign accounts or foreign income
- IRS Criminal Investigation has contacted you, and you have not yet answered
- You inherited or opened an account overseas and have no idea what you owe
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Why Choose MD Sullivan Tax Group
Foreign account cases sit where tax law, criminal exposure, and IRS procedure meet. Few firms are comfortable in all three. Our team is, and that is why clients bring the cases they fear most to an FBAR attorney at our firm.
- Our founder, Michael D. Sullivan, was a former IRS Revenue Officer and Offer in Compromise specialist who has been in private practice since 1983
- A full team on your case: tax attorneys, CPAs, enrolled agents and former IRS agents working together
- Over 130 years of combined IRS experience across the team
- We know how the IRS thinks because many of us used to work there
- A privilege-first process: an FBAR lawyer leads, and accountants join under a Kovel arrangement
- FBAR criminal penalties and civil exposure reviewed before any form is filed
- Nationwide representation, with a foreign bank account tax attorney handling the IRS so you never have to
- Confidential, judgment-free conversations from the first call
The Safest Time to Deal With This Was Years Ago. The Next Best Time Is This Week.
You do not have to carry this alone, and you do not have to guess. Sit down with our FBAR attorney, backed by former IRS agents who have seen how these cases end when they are handled early and how they end when they are not.
One confidential conversation can show you where you stand and what to do next.
Call us or book your free consultation now. The sooner we talk, the more options you have.
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FAQs
When willfulness or criminal risk is on the table. That includes deliberately hidden accounts, large unreported offshore income, or contact from IRS Criminal Investigation. An attorney offers legal privilege, and can bring in accountants under that privilege through a Kovel arrangement, so your conversations stay protected.
Knowing about the FBAR rule and choosing not to file, or acting with reckless disregard. Courts have pointed to signs like answering 'no' to the foreign account question on Schedule B, moving money to avoid detection, or ignoring an accountant's advice. Willful blindness can count as willful too.
It is the path for people whose non-compliance was willful. You request preclearance on Form 14457 before the IRS contacts you, then disclose and pay tax, interest and set penalties for the covered years. In exchange, the IRS generally does not recommend criminal prosecution.
Streamlined is only for non-willful cases and carries low or no penalties. Voluntary Disclosure is for willful cases and costs more, but protects against prosecution. Signing a false non-willful certification to get into Streamlined can create serious criminal risk, so this choice needs careful review.
Yes. A willful penalty can reach 50% of the account balance for each year, and it can be applied to several years and several accounts. Stacked together, the total can exceed what was ever in the account. That is why early legal strategy matters so much.
Most people will not. Prosecution usually targets active concealment, large amounts, or lying to agents. Coming forward before the IRS contacts you, through the right disclosure path, greatly reduces the risk of criminal charges.
