2026 IRS Voluntary Disclosure of Foreign Bank Accounts: File Before It’s Too Late

Taxpayers who have failed to report their foreign bank accounts to the federal government can come into compliance by filing a voluntary disclosure. But strict filing requirements (including strict deadlines) apply, and once it is too late to file, taxpayers must be very careful to avoid sharing information that the IRS could use to pursue civil or criminal enforcement.

Federal law requires U.S. taxpayers to report foreign bank accounts to the government annually. Each year, individual and corporate taxpayers who have an interest in offshore accounts with an aggregate value greater than $10,000 must file a Report of Foreign Bank and Financial Accounts (FBAR) no later than October 15. Those who don’t are noncompliant and must come into compliance to avoid high-risk scrutiny from the IRS. Learn more from Boston tax lawyer Kevin E. Thorn, Managing Partner of Thorn Law Group:

What Are Your Options if You Missed the FBAR Filing Deadline?

Taxpayers who miss the FBAR filing deadline have two primary options, though each applies in different circumstances. To come into compliance, taxpayers can either:

• Submit a streamlined filing for non-willful FBAR violations; or
• Submit a voluntary disclosure for willful FBAR violations.

Individual and corporate taxpayers who are behind on their FBAR filings should consult with experienced tax counsel to determine whether the IRS is likely to deem their delinquency to be “willful” under the circumstances at hand. Willful and non-willful delinquencies carry different risks, and streamlined filings and voluntary disclosures involve different procedures.

What is the Deadline for Submitting a Streamlined Filing or Voluntary Disclosure?

Generally, taxpayers can submit a streamlined filing or voluntary disclosure until the IRS opens an audit or investigation. Once an audit or investigation is underway, any efforts to come into compliance are no longer considered “voluntary,” and the benefits of voluntary compliance are no longer available.

Are There Risks Involved with Voluntary Disclosure?

Yes. While voluntary disclosure is the primary way to remedy delinquent FBAR filings, it still carries risks when you voluntarily disclose noncompliance to the IRS. For example, if the IRS does not “accept” a taxpayer’s voluntary disclosure, it can use the information disclosed to pursue civil or criminal enforcement.

How Thorn Law Group Can Help

We assist individual and corporate taxpayers with all aspects of remedying FBAR noncompliance. If you need to consider streamlined filing or voluntary disclosure, we can help you make informed, strategic decisions about how to proceed. We can also communicate with the IRS on your behalf; and, if it is too late to come into compliance voluntarily, we can help you fight to avoid unnecessary consequences.

Request an Appointment with Boston Tax Lawyer Kevin E. Thorn

If you need to know more about federal offshore account disclosure compliance, we encourage you to contact us promptly. Call 617-692-2989 or contact us confidentially online to request an appointment with Boston tax lawyer Kevin E. Thorn, Managing Partner of Thorn Law Group.