Compliance Assistance That Stops Penalties Before They Start
If you hold money overseas and skipped the FBAR, we’ll help you understand your circumstances and navigate the next steps.
MD Sullivan Tax Group is a team of tax attorneys, CPAs, enrolled agents, and former IRS agents with 130+ years of combined IRS experience.
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Missed FBAR Filing: Are You One of These People?
The FBAR (Report of Foreign Bank and Financial Accounts) is a yearly form for anyone whose foreign accounts held more than $10,000 combined at any point in the year.
You are probably in the right place if you:
- Hold a green card and keep a bank account in your home country
- Moved abroad for work and opened a local account for your salary
- Inherited a foreign account from a parent or relative
- Earn from overseas clients and get paid into a foreign account
None of this is hiding money. It is a form nobody told you about. The IRS treats an honest mistake (called non-willful) very differently from deliberate concealment, and your filing has to show which one you are. Late FBAR filing lets you correct the record on your own terms.
Heading: Your Foreign Account Is Not a SecretBody: Foreign banks report to the IRS. Late FBAR filing on your terms beats a notice on theirs. Former IRS agents build your filing the right way. CTA: Let’s File Your FBAR |
Delinquent FBAR Submission Procedures Changed on July 1, 2026
For years, you had to file your overdue FBARs with an explanation, and there was no penalty if you had already reported and paid tax on the income. On July 1, 2026, the IRS removed it. The delinquent FBAR submission procedures no longer come with a written no-penalty guarantee.
That makes the way you file, and the words you use, matter more than before. We build every package so the record reads as what it is: an honest mistake, corrected.
| Let’s Help You File FBAR Safely |
Which Route Fits You: Late FBAR Filing or Streamlined FBAR
Your route depends on one question: did you also leave foreign income off your tax returns?
- You reported all the income. Only the FBAR is missing. You file the overdue reports with an honest reason. A penalty is less likely, though no longer promised in writing.
- You also skipped foreign income. Filing the FBAR alone is not enough. The Streamlined Filing Compliance Procedures let non-willful taxpayers amend 3 years of returns and file 6 years of FBARs. US residents pay a 5% penalty on the foreign assets. People living abroad who qualify pay no penalty. This is the streamlined FBAR route.
- The IRS already contacted you. Your options shrink. IRS contact usually ends eligibility for the Streamlined Procedures and voluntary routes. Get representation before you respond.
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How to File a Late FBAR Without Making It Worse
You submit FinCEN Form 114 online through the BSA E-Filing System, the same way you would file on time. The form asks you to pick a reason for filing late. You attach a clear, honest explanation. If you also have unreported foreign income, you fix your tax returns at the same time.
The form is simple. The mistakes happen around it:
- A vague reason that invites questions instead of answering them
- Filing one year when the IRS can look back six
- Filing the FBAR and leaving the tax returns untouched
Filing all six years in one clean package is the standard approach. Filing fewer can leave open years exposed.
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What Our FBAR Filing Help Includes
Our FBAR filing help covers every part of late FBAR filing and everything the filing touches:
- A full review of every foreign account you hold, including ones you forgot about
- FinCEN Form 114 prepared for each missing year, usually the last six
- A written reasonable-cause statement that explains your situation honestly
- Amended tax returns when foreign income was left off
- A complete Streamlined submission if you qualify
- Direct representation if the IRS writes, calls or opens an exam
One team handles the FBARs and the tax returns. Nothing slips between two preparers.
How We Get You Clean, Step by Step
- The Account Hunt. We list every foreign account, its highest balance each year and who held it. Bring what statements you have. We help track down the rest.
- The Honesty Audit. Before anything is filed, we read your facts the way an IRS examiner would. This tells us how your story sounds and what needs explaining.
- The Route Call. We choose between a standalone late FBAR filing, the Streamlined Procedures, or another path, and we explain the choice in plain English.
- The One-Package Build. FBARs, amended returns, and your written explanation go out together, so no year is left hanging.
- The Handoff. We file, and we field the IRS. If they respond, you never have to speak to them.
What to expect: The timeline depends on how many accounts and years are involved. We confirm it during your free consultation, before you commit to anything.
Why Clients With Foreign Accounts Choose MD Sullivan Tax Group
You are handing over a sensitive part of your finances. You should know who you are trusting.
- 130+ years of combined IRS experience. Our tax attorneys, CPAs, enrolled agents and former IRS agents know how these filings are reviewed from the inside.
- A founder who worked inside the IRS. Michael Sullivan is a former IRS Revenue Officer and Offer in Compromise specialist, in private practice since 1983.
- Author and media voice. Michael co-authored an Amazon #1 IRS guide and has appeared on Fox Business and NBC.
- IRS Representation. After we file, we handle IRS contact so you do not have to.
- Nationwide reach. We work with US residents and Americans living abroad, from any state.
- A free first conversation. You leave the consultation knowing your route and your risk, with no obligation.
| Talk to Former IRS Agents |
Every Month You Wait Makes Your Story Harder to Tell
Foreign banks now report American account holders to the IRS. The information is already moving, whether you file or not.
Right now, the voluntary routes are open. The person who files before the IRS letter arrives tells one story: I found the mistake and fixed it. The person who files after tells a different one, with fewer options and much less control.
Late FBAR filing done right costs far less than the penalty it prevents. Our team has the IRS experience, the six-year process, and the representation to close this for good.
Stop carrying this. Let us carry it.
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FAQs
File FinCEN Form 114 online through the BSA E-Filing System, the same way you would file on time. The form asks you to choose a reason for filing late. Attach a clear, honest explanation. If you also have unreported foreign income, fix your tax returns at the same time.
Not publicly. On July 1, 2026, the IRS removed the webpage that promised no penalty for qualifying late FBARs. The IRS internal manual (IRM 4.26.16.3.11) still contains similar guidance for examiners, but taxpayers can no longer point to a published no-penalty promise.
Not automatically. FBAR penalties are discretionary and usually only considered during an exam. If you reported all the income from the accounts and paid the tax, a penalty is less likely, but no longer promised in writing. The maximum non-willful penalty is $16,536 per late report.
It was due April 15, 2026, with an automatic extension to October 15, 2026. If you file your 2025 FBAR by October 15, 2026, it counts as on time, and the removal of the late-filing procedure does not affect it.
Then the late-FBAR route alone is not enough. The Streamlined Filing Compliance Procedures let non-willful taxpayers amend 3 years of returns and file 6 years of FBARs. US residents pay a 5% penalty on the foreign assets. People living abroad who qualify pay no penalty.
Usually the last six. That matches both the Streamlined Procedures and the six-year window the IRS generally has to assess civil FBAR penalties. Filing fewer can leave open years exposed. Filing all six in one clean package is the standard approach.
Your options shrink. IRS contact usually ends eligibility for the Streamlined Procedures and voluntary routes. At that point, what you file and how you explain it can decide whether the case is treated as willful, so get representation before you respond.
