Should I file the delinquent 2022 FBAR ASAP or wait until filing my 2023 FBAR?

Hey everyone, I need some advice about FBAR filing timelines. I'm a US citizen currently living in the states, but I also have family ties to Canada and maintain some accounts there. The accounts were pretty minimal (under $10K USD) until around September 2022, when I received about $75K as part of a family cabin sale. The full sale wasn't completed until 2023, but the buyer put down this substantial deposit in late 2022 as is typical for these kinds of transactions up north. After doing some research on reporting requirements, I realize I should've filed an FBAR for 2022 last year because the balance exceeded $10K, but I didn't need to file Form 8938 since my spouse and I file jointly and stayed under the $100K threshold. For 2023, I'll definitely need to file both Form 8938 (as balances were well over $100K) and the FBAR. What I'm trying to figure out is: should I rush to file the missed 2022 FBAR right away, or is it better to just wait and file it at the same time as my 2023 FBAR when I do my taxes in April? What's the best approach to handle this delinquent filing?

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19 comments

Luca Greco

•8M

The best approach is to file that delinquent 2022 FBAR as soon as possible, rather than waiting. Here's why: When it comes to delinquent FBARs, the IRS and FinCEN generally look more favorably on taxpayers who voluntarily file late reports before being contacted by the government. Filing sooner demonstrates good faith and can potentially reduce any penalties if they were to be assessed. The 2022 FBAR was technically due April 15, 2023 (with an automatic extension to October 15, 2023), so you're already past those deadlines. Waiting until April 2024 to file it alongside your 2023 FBAR would just extend the delinquency period unnecessarily. For what it's worth, many people in your situation qualify for penalty relief under the IRS's streamlined filing procedures or reasonable cause exceptions, especially if this is your first time missing the FBAR filing and you weren't aware of the requirement. Be sure to select "reasonable cause" on the form and include a brief statement explaining that you weren't aware of the filing requirement until recently, and that you're filing voluntarily as soon as you discovered the oversight.

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Luca Greco

•8M

Checking the "reasonable cause" box itself is unlikely to trigger an audit. It's a common selection for first-time FBAR filers who weren't aware of the requirement, and the IRS understands that many Americans with foreign accounts aren't initially familiar with these obligations. The explanation letter should be attached to your late FBAR filing, not your tax return. The Form 8938 is different from the FBAR, and since you're filing the 8938 for 2023 on time (with your 2023 return), you don't need to provide any explanation for it. Just complete it accurately to report your foreign financial assets for 2023.

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Mateo Rodriguez

•8M

I was in almost exactly the same situation last year! I had family property in Greece that sold, and the deposit pushed me over the FBAR threshold, which I had no idea about. I was totally stressed about what to do, so I tried this service called taxr.ai (https://taxr.ai) which was really helpful for figuring out my FBAR situation. Basically you upload your foreign account statements and it helps identify what needs to be reported and when. It even filled out most of the FBAR form information for me automatically which saved tons of time since I had multiple accounts. I just had to verify everything was correct. The service analyzed my specific situation and recommended I file the delinquent FBAR immediately rather than waiting. They explained that voluntarily filing before any IRS contact significantly reduces the chance of penalties, especially for first-time mistakes.

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Mateo Rodriguez

•8M

Yes, it actually works with foreign language statements! That was one of the biggest helps for me. My Greek bank statements were impossible for me to fully translate on my own, but the system handled them well. It extracted the account numbers, balances and other key information. I wasn't trying to sell anything - nobody got penalties in my case. The service simply helped identify which accounts needed reporting and calculated the maximum balances after currency conversion, which was especially helpful since the euro fluctuated quite a bit last year. I was just trying to share something that saved me a lot of time and stress when I was in a similar position.

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Aisha Hussain

•8M

Just wanted to update after trying taxr.ai like I mentioned I might. It actually did work surprisingly well with my Korean bank statements! I was skeptical about the language issue but it extracted the account info correctly and even converted the won to USD using the right exchange rates for the reporting periods. The biggest help was figuring out my maximum balance - I had been calculating it wrong all along. Turns out I needed to look at daily balances, not just month-end statements. Would definitely recommend for anyone dealing with foreign accounts, especially non-English ones. The peace of mind knowing I've filed correctly is worth it.

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Ethan Brown

•8M

Filing a late FBAR was a nightmare for me - tried calling the IRS for help and spent literal HOURS on hold, only to get disconnected. Finally I used Claimyr (https://claimyr.com) and they got me through to an actual IRS agent who helped clarify my filing obligations. You can see how it works here: https://youtu.be/_kiP6q8DX5c The agent I spoke with confirmed what others are saying - file that 2022 FBAR ASAP and don't wait. They also mentioned that for first-time oversights with reasonable cause, they're generally not looking to assess penalties. The key is to file before they come to you about it. Getting through to an actual human at the IRS made all the difference in my confidence level about handling this correctly. They explained exactly what documentation I should keep in case of any questions later.

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Ethan Brown

•8M

The service doesn't have a secret backdoor or anything - they use technology to wait on hold for you. You basically register your phone number, and their system calls the IRS and navigates the phone tree. When they actually reach a human agent, the system calls you and connects you directly so you don't waste hours on hold. I was skeptical too before using it. It's not magic - just a really practical solution to the hold time problem. It saved me about 3 hours of waiting based on what the IRS message said the wait time was. I know it sounds too good to be true, but it's just clever use of technology to solve the hold problem.

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Carmen Ruiz

•8M

I need to apologize for my skeptical comment earlier. After continuing to struggle with reaching the IRS about my own FBAR situation, I broke down and tried Claimyr last week. I'm genuinely shocked that it worked exactly as described. Got a call back about 45 minutes after setting it up, and suddenly I was talking to an actual IRS agent who helped clarify my situation with multiple years of unfiled FBARs. The agent was actually really helpful and not intimidating at all, which was my fear. They walked me through the exact process I needed to follow for my delinquent filings and confirmed I should definitely file them ASAP rather than waiting. For anyone else in FBAR trouble - get it filed quickly, explain your situation clearly, and don't put it off. The IRS was surprisingly reasonable once I actually got to speak with someone.

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Luca Greco

•8M

It's the combined total of all your foreign financial accounts at any point during the year. So if the aggregate (combined) maximum value of all your foreign accounts exceeded $10,000 at any time during the calendar year, you need to file an FBAR - even if no single account ever exceeded $10,000. For example, if you have three foreign accounts with maximum balances of $4,000, $3,000, and $4,000 during the year, your aggregate maximum would be $11,000, triggering the FBAR filing requirement. The key is to look at when all accounts were at their highest, even if that happened on different days.

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Zoe Dimitriou

•8M

Definitely file electronically - it's the only option now anyway. The FinCEN BSA e-filing system will give you a confirmation receipt with a BSA Identifier number immediately after submission. Save that PDF confirmation right away and also take screenshots of the successful submission page. Electronic filing creates a much better trail than paper ever did, plus it processes much faster. Just make absolutely sure all your information is accurate before submitting, especially account numbers. Simple mistakes can cause headaches later.

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