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The IRS recently reiterated procedures for filing late FBAR forms. Taxpayers will not have to use the current streamlined tax filing program or the more invasive OVDP/OVDI program to catch up on late FBAR forms.

To qualify for filing late FBARs without fear of penalty taxpayers:

  • should have not already filed FBARs for any other years
  • are not under examination or audit by the IRS
  • have not been contacted by the IRS with respect to late FBARs


In order to file late FBARs taxpayers should:

  • Follow the instructions for form 114 here
  • Attach a statement to the electronic filing explaining why the FBARs are late (this step doesn’t make sense as the new form is currently filed electronically and a reason can be outlined on the first page of the form, see below)
  • Include a reason for late filing on the first page of form 114
  • File the form electronically here

The IRS stated in their recent tax alert that penalties would not be imposed on late FBAR submissions if the taxpayer properly reported all income and paid required tax on income related to non-disclosed accounts, and has not been contacted by the IRS in regards to an income tax examination or audit with respect to years which late FBARs are submitted.

If you have any question on how to file your delinquent FBAR forms please give us a call at 250-381-2400 to discuss your options.

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Philip Hogan

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The information contained in this article is for general use only and should not be viewed as professional advice. Accounting and tax rules and regulations regularly change and individuals should contact a competent professional to obtain accounting and tax advice based on their specific situation.


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