FBAR Filing Attorneys Who Stop Penalties Before The IRS Comes Knocking

$10,000+ In Foreign Accounts? One Missed FBAR Can Cost You Half Of It.

You found out about the FBAR filing requirement. Now you’re wondering if you’re already late, how much this is going to cost, and whether the IRS already knows about your accounts.

Our tax attorneys have filed thousands of FBARs and eliminated millions in penalties. On your first call, we tell you exactly where you stand and what it takes to fix it. No guesswork.

40+ Years Combined Tax Law Experience
$128,000,000+ Saved From IRS Penalties
Real Tax Attorneys (Not Preparers)
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Missing FBAR Filings Can Cost 50% of Your Account Balance Per Year

We help clients file current FBARs, correct past non-compliance through voluntary disclosure programs, and defend against IRS penalty assessments.

If your foreign accounts total more than $10,000 at any point during the year, you must file FinCEN Form 114 by April 15 (automatic extension to October 15).

Non-willful penalties can reach $16,536 per late FBAR report under the current inflation-adjusted cap. Willful penalties can reach the greater of $165,353 or 50% of the account balance. The IRS can review six years of missing FBARs.

Our Role as Your FBAR Filing Attorney

Figure out if you need to file: We review your foreign accounts and tell you exactly which forms you need and when they're due.
Prepare and file everything for you: We fill out FinCEN Form 114, add up your account balances, and submit everything electronically by the deadline.
Fix past mistakes with lower penalties: If you missed filing in prior years, we help you catch up through programs that reduce or eliminate penalties.

Fight IRS penalties: We respond to IRS notices, explain why penalties shouldn't apply, and negotiate to reduce what you owe.
Make sure everything matches: We coordinate your FBAR with your tax return so all your foreign account information lines up correctly.
Keep your information private: Attorney-client privilege means the IRS can't force us to share what you tell us about missed filings or unreported accounts.

Why Clients Choose Our Tax Law Firm

Our clients come to us when the stakes are high. Everyday taxpayers, Business owners, professionals, crypto investors, and high-income earners who can’t afford mistakes. They trust Silver Tax Group for one reason: we get results.

Led by
Chad C. Silver, Esq.

Chad C. Silver, Managing Partner, has dedicated his career to defending taxpayers from aggressive IRS enforcement. He is a member of the National Association of Tax Professionals (NATP) and the American Bar Association (ABA), and is admitted to practice before the United States Tax Court and the State Bar of Michigan.

Chad authored Stop the IRS, a guide for individuals and business owners seeking to understand and resolve federal tax issues. His leadership drives Silver Tax Group’s mission—to deliver lawful, strategic, and permanent solutions for clients across the nation.

What Is FBAR and Who Has to File?

FBAR stands for Report of Foreign Bank and Financial Accounts. You file this form when your foreign accounts total more than $10,000 at any time during the year.

The $10,000 limit applies to all your foreign accounts combined, not each account separately. For example, if you have $6,000 in a London bank and $5,000 in a Toronto investment account at the same time, you crossed the $10,000 limit and must file.

U.S. citizens, residents, corporations, partnerships, LLCs, trusts, and estates all need to file FBAR when they meet the requirements.

Who We Help With FBAR Compliance

We handle all FBAR filing needs for individuals, businesses, and trusts with foreign accounts. Our tax attorneys prepare this year’s filings, fix missed filings from past years, defend against penalties, and represent you during IRS audits. When you work with our attorneys, attorney-client privilege protects what you tell us. CPAs and tax preparers don’t have this same protection.

High-Net-Worth Individuals With Large Foreign Account Balances

You have foreign investment accounts, offshore bank accounts, or international real estate worth more than $10,000 total. Missing FBAR filings could cost you hundreds of thousands in penalties. We handle your filings correctly to meet all IRS requirements while keeping your financial information as private as the law allows.

People Who Missed FBAR Deadlines in Past Years

You just learned about FBAR filing requirements, maybe years after you should have filed. The IRS hasn’t contacted you yet. We check if you qualify for programs that reduce or eliminate penalties. Many clients pay zero penalties when they file correctly before the IRS finds out.

Dual Citizens With Accounts in Your Home Country

You’re a citizen of both the U.S. and another country. You have bank accounts, retirement accounts, or investments in your home country. U.S. law requires you to file FBAR even if you live abroad or think of yourself as mainly a citizen of the other country.

Business Owners Who Can Sign on Company Accounts

You can sign checks or move money in foreign business accounts as an officer, employee, or authorized signer. You must file FBAR personally even if you don’t own the account. This applies to corporate accounts, partnership accounts, and any client accounts you control.

Expats: Americans Living Abroad With Foreign Bank Accounts

You moved overseas for work, retirement, or family reasons. You opened local bank accounts to pay bills and handle daily expenses. Even though you live outside the U.S., you must still file FBAR if your foreign accounts total more than $10,000. We help expats meet U.S. filing requirements while living abroad.

People Who Inherited Foreign Accounts or Received Large Foreign Gifts

You inherited money from a relative who lived overseas, or someone gave you a large gift from a foreign account. These accounts now put you over the $10,000 FBAR filing threshold. We help you report inherited accounts and foreign gifts correctly to avoid penalties for accounts you didn’t even know you needed to report.

Missed Past FBAR Deadlines? We Can Help.

See if you qualify for penalty-free voluntary disclosure through Delinquent FBAR Submission Procedures or reduced penalties through Streamlined Filing Compliance Procedures. We've helped hundreds of clients resolve past non-compliance with minimal penalty exposure.

Discuss Late Filing Options

Complete FBAR Filing Services From Licensed Tax Attorneys

As part of our international tax services, we handle all FBAR filing needs for individuals, businesses, and trusts with foreign accounts. Our tax attorneys prepare current-year filings, fix missed filings from past years, defend against penalties, and represent you during IRS audits.

Current Year FBAR Filing

✓FinCEN Form 114 preparation and electronic filing
✓Calculate total account balances to check filing requirements
✓Report accounts where you can sign checks for your employer or business
✓File jointly with your spouse when both have foreign accounts
✓Meet deadlines (April 15 with automatic October 15 extension)

Late FBAR Filing and Penalty Relief

✓Delinquent FBAR filing with zero penalties (when you qualify)
✓Streamlined Filing Procedures for reduced or eliminated penalties
✓IRS Voluntary Disclosure for serious non-compliance cases
✓Prepare up to 6 years of missed FBARs
✓File amended tax returns for unreported foreign income

FBAR Penalty Defense

✓Request penalty removal for reasonable cause
✓Prove your violations were unintentional, not willful
✓Negotiate lower penalties with IRS examination division
✓File appeals when IRS assesses unfair penalties
✓Defend against 50% willful FBAR penalties

IRS Audit and Examination Defense

✓Represent you during FBAR audits
✓Respond to IRS document requests
✓Limit what the IRS can investigate
✓Prevent criminal investigation referrals
✓Negotiate settlements with IRS agents

Related International Tax Forms

✓Form 8938 (report foreign financial assets over $50,000)
✓Form 3520 (report foreign trust transactions and gifts)
✓Form 5471 (report ownership in foreign corporations)
✓Form 8865 (report foreign partnership interests)
✓Schedule B (answer foreign account questions on tax return)

How Our FBAR Filing Process Works: From Consultation to Submission

We handle everything from collecting your account statements to filing electronically with FinCEN. Our process finds ways to reduce or eliminate penalties while keeping your information protected. Current-year filings take 2-3 weeks. Fixing missed filings from past years takes 4-8 weeks depending on how complex your situation is.

Step 1: Free Private Consultation and Case Review

We review your foreign accounts, check what you need to file, and look at any missed filings. Our FBAR tax attorneys figure out which accounts you need to report, whether you qualify for penalty reductions, and get fully compliant. You get answers about what you need to file, timeline, possible penalties, and our pricing.

Step 2: Collect Your Foreign Account Statements

We compile statements showing your highest account balances during the year. For this year’s filing, you give us statements from all your foreign banks. For missed filings from past years, we collect 6 years of statements. We help you get old statements from foreign banks.

Step 3: Prepare Your FBAR and Check Everything

We fill out FinCEN Form 114 with account details, calculate balances, and mark account ownership. We validate the $10,000 filing requirement, and check if you need to file Form 8938 (FATCA). For late filings, we prepare everything, including amended tax returns and statements explaining why you filed late.

Step 4: File Electronically Through FinCEN's System

We submit your FBAR online through FinCEN. You get a confirmation email and filing receipt. For current-year filings, we make sure everything is filed timely. For late filings, we include a statement explaining why you’re late and follow the correct procedures for penalty relief programs.

Step 5: Watch for IRS Letters and Handle Any Follow-Up

After filing, we watch for letters from the IRS. If the IRS contacts you, we handle everything. For clients using penalty relief programs, we answer IRS questions and negotiate to reduce penalties. We set up reminders for your yearly FBAR filings and stay available if you open new foreign accounts or have questions about reporting changes.

Step 6: Your FBAR Compliance is Complete

Your FBAR filing is accepted and you’re in full compliance with IRS requirements. If you used a penalty relief program, we confirm the IRS accepted your submission with reduced or zero penalties. You receive copies of all filed forms for your records. We stay available if you have questions or need help with next year’s filing.

FBAR Penalties: What You Face for Not Filing

All FBAR penalties fall into two types: unintentional and intentional. The difference determines whether you pay thousands or millions in penalties.

A non-willful penalty may apply when the failure came from negligence, an honest mistake, or a good-faith misunderstanding. The current maximum is $16,536 per late annual report. The Supreme Court’s Bittner v. United States decision applies this penalty once per annual report.

A willful penalty may apply when the taxpayer knowingly violated the filing rule or recklessly ignored it. The current maximum is the greater of $165,353 or 50% of the account balance. The IRS may assess a penalty for each willful violation.

How the IRS Decides If You Hid Your Accounts on Purpose

The IRS looks at several things when deciding if your FBAR violations were intentional:

✓Did you check “yes” to the Schedule B foreign account question on your tax return but not file FBAR? This shows you knew about the offshore accounts.
✓Did you get professional tax advice that mentioned FBAR?
✓Did the accounts earn income you didn’t report?
✓Did you use the accounts for transactions meant to hide them?
✓Did you open accounts in countries known for bank secrecy?
✓Did you hold accounts through fake companies or other people’s names?

Even wealthy people with complex finances can prove their mistake was honest with the right documentation and legal arguments.

Criminal FBAR Penalties and Jail Time

Intentional FBAR violations can lead to criminal charges. Maximum criminal penalties include up to 5 years in federal prison and fines up to $250,000. The IRS Criminal Investigation Division pursues criminal cases when they suspect you deliberately hid foreign accounts.

Timely voluntary disclosure may reduce criminal exposure in qualifying cases. Eligibility generally closes after the IRS starts an examination or investigation. A tax attorney should review the facts before any filing. This makes early consultation with a tax attorney critical when you discover past missed filings.

Missed Past FBAR Deadlines? Three Ways to Fix It With Lower or Zero Penalties:

The IRS offers three programs for people who didn’t file FBARs in past years. Which program you use determines if you pay penalties and how much. We look at your accounts, how many years you missed, and whether you reported the income. Then we recommend the path that gives you the lowest penalties.

1. Delinquent FBAR Submission Procedures (Zero Penalties)

This program lets you file late FBARs with no penalties if you meet three rules: you reported all your foreign account income on your tax returns, you paid all taxes owed, and you didn’t know you had to file FBARs. You file up to 6 years of missed FBARs with a letter explaining why you’re late.

2. Streamlined Filing Procedures (5% Penalty or Zero)

Streamlined procedures apply when you didn’t report your foreign accounts AND the income they earned, but you didn’t hide them on purpose. Two versions exist based on where you live:

Both programs require you to sign a statement saying you didn’t hide your accounts on purpose, you just made an honest mistake or didn’t know the rules.

3. IRS Voluntary Disclosure Practice (For Intentional Hiding)

If you knew about FBAR rules and chose not to file, you can’t use the other programs. The Voluntary Disclosure Practice is your only option. This program prevents criminal charges but has high penalties, usually 50% of your highest total account balance.

The IRS calls it intentional when you got advice about FBAR but didn’t file, you answered “yes” to foreign account questions on Schedule B but skipped filing FBAR, or you moved money around to stay under the $10,000 limit.

Common Questions & Answers About FBAR Filing and Compliance

What is the FBAR filing deadline?

The FBAR filing deadline is April 15 each year, with an automatic extension to October 15 requiring no formal request.

Unlike tax return extensions that need Form 4868, the FBAR extension is automatic. You don’t file anything to get the October 15 deadline. However, the IRS can still charge late filing penalties if you miss October 15. Natural disasters can extend deadlines even further in affected areas. See our FBAR reporting guide for more information.

Do I need to file FBAR if I already reported my foreign accounts on my tax return?

Yes. Reporting foreign account income on your tax return does not replace the separate FBAR filing requirement through FinCEN’s system.

FBAR and your tax return are separate filings that go to different agencies. Your tax return goes to the IRS. FBAR (FinCEN Form 114) goes to the Financial Crimes Enforcement Network. You must file both when your foreign accounts total more than $10,000. Many taxpayers face penalties because they thought reporting the income was enough, even though they paid all taxes owed.

What happens if I file my FBAR late?

Late FBAR filing can result in penalties from $10,000 per year for unintentional violations to 50% of your account balance per year for intentional violations.

The IRS treats taxpayers who voluntarily file late FBARs before IRS contact differently than those discovered through audits. Voluntary disclosure through the right programs often eliminates or reduces penalties significantly. Delinquent FBAR Submission Procedures can result in zero penalties when you meet the requirements. Our attorneys have helped hundreds of clients file late FBARs with minimal penalties through smart program selection.

How does the IRS find out about unreported foreign accounts?

Foreign banks report U.S. account holder information directly to the IRS through FATCA information exchange agreements with foreign governments.

The Foreign Account Tax Compliance Act requires foreign banks to report accounts held by U.S. persons or face big penalties. Over 100 countries participate in automatic information exchange. The IRS receives detailed reports including account holder names, addresses, taxpayer ID numbers, account balances, and transaction information. Swiss bank secrecy no longer protects U.S. taxpayers. Banks in the Cayman Islands, Singapore, Hong Kong, and other offshore locations report to the IRS.

Can I file FBAR myself or do I need a tax attorney?

You can file FBAR yourself through FinCEN’s online system, but tax attorneys provide representation benefits that CPAs and tax preparers cannot offer.

Figuring out filing requirements, calculating total balances, identifying accounts where you can sign checks, and coordinating with Form 8938 requirements needs tax expertise. For late filings, voluntary disclosures, or penalty defense, attorney representation provides privilege protection and negotiation power. The IRS cannot force us to share what you tell us about past missed filings.

What is the difference between FBAR and Form 8938?

FBAR reports foreign financial accounts to FinCEN when total balances exceed $10,000, while Form 8938 reports specified foreign financial assets to the IRS.

FBAR and Form 8938 have different filing limits, go to different agencies, and cover partly overlapping asset types. Form 8938 limits are higher: $50,000 for U.S. residents, up to $600,000 for people living abroad. Form 8938 files with your tax return. Form 8938 includes some assets FBAR doesn’t cover, like foreign stock held directly. Many taxpayers must file both forms for the same accounts.

How much does FBAR filing cost with a tax attorney?

FBAR filing fees range from several hundred dollars for current-year filings to several thousand for fixing multiple years of missed filings.

Current-year FBAR filing for straightforward situations typically costs $500 to $1,500 depending on the number of accounts and complexity. Fixing multiple years through Streamlined Procedures costs $3,000 to $8,000 depending on the number of years, accounts, and whether you need amended tax returns. IRS audit defense and penalty reduction requests are priced separately based on case complexity. We provide flat-fee quotes before starting work.

Can the IRS seize my foreign bank accounts for FBAR violations?

Yes, the IRS can levy foreign bank accounts to collect unpaid FBAR penalties after completing the examination and assessment process. The IRS can also seize domestic assets to satisfy FBAR penalty assessments. Getting in compliance before penalty assessment provides the best protection.

Schedule Your Free FBAR Compliance Consultation Today

Our tax attorneys provide confidential consultations to evaluate your filing requirements, penalty exposure, and compliance options.