The U.S. Treasury requires U.S. citizens and green card holders to declare their non-U.S. financial accounts and remain compliant with FBAR (Foreign Bank Account Report, FinCEN Form 114) filings for the past six years.
FBARs are required only if the aggregate balance of your non-U.S. financial accounts exceeded $10,000 at any point during the year, even if only for one day.
If you filed your U.S. tax returns but have not filed FBARs, your options depend on whether all interest income from your foreign accounts was reported and whether you are subject to additional reporting requirements:
All interest reported on original returns → File delinquent FBARs under the Delinquent FBAR Submission Procedure (no amended tax returns required).
Interest not reported on original returns → File three amended tax returns + six FBARs through the Streamlined Foreign Offshore Procedures.
Form 8938 (FATCA) was required but not filed → File three amended returns, Forms 8938, and six FBARs through the Streamlined Foreign Offshore Procedures.
For more details, see Difference between FinCEN Form 114 and Form 8938.
If you are not up to date on U.S. tax returns (not current with U.S. income tax reporting), you may be able to take advantage of the following IRS amnesty programs:
Delinquent international information return submission procedures (if you filed tax returns but never filed Form 5471 and/or 3520-A).
What is the Delinquent FBAR Submission Procedure?
The Delinquent FBAR Submission Procedure is a program that allows U.S. taxpayers to catch up on unfiled FBAR filings without facing penalties, provided that:
You reported all related (interest) income on your U.S. tax returns.
You are not under IRS audit or investigation.
The IRS has not contacted you about missing FBARs.
Unlike the Streamlined Procedures, residency status is not relevant — both U.S.-based and overseas taxpayers can qualify.
Who is eligible?
You may qualify if:
You did not file one or more required FBARs in prior years.
You properly reported all taxable income from your foreign accounts on your U.S. tax returns.
You are not currently under IRS audit or investigation.
The IRS has not already notified you about delinquent FBARs.
If all of the above apply, you can file late FBARs under the Delinquent FBAR Submission Procedure penalty-free.
Filing with TFX
To file past-due FBARs with TFX, follow these steps:
Ensure that all related income from your foreign accounts was included on your prior tax returns.
Electronically file delinquent FBARs directly through your TFX account using our automated FBAR filing service.
Pay the fee: $85 per tax year.
⚠ Note: The 20% multi-year discount does not apply to FBAR filings.
By filing through TFX, you ensure your FBARs are submitted correctly and securely — without having to navigate FinCEN’s BSA e-filing system on your own.