Should I file the delinquent 2022 FBAR asap or wait until I file the 2023 FBAR?

That makes sense, but what's the actual process for filing a late FBAR? Do I just go through the normal online BSA filing system and check some kind of "late filing" box? And will they automatically assess penalties or do they review each case?

Yes, you'll file the late FBAR through the BSA E-Filing System, the same way you'd file a current FBAR. When filing, you'll be asked to select a reason for filing late. Choose the option that best explains your situation and provide a brief statement about not being aware of the requirement when your account temporarily exceeded the threshold due to the real estate deposit. The system doesn't automatically assess penalties. The IRS will review late filings, and they generally waive penalties when there's reasonable cause, you've voluntarily filed before any IRS contact, and you've properly reported all taxable income from these accounts on your tax returns.

How exactly does taxr.ai work? Does it just give general advice or does it actually help with the filing process itself? I have a similar situation with accounts in Germany that I'm not sure if I need to report.

I'm a bit skeptical of these tax tools. How confident are you that the advice was actually correct? I've been burned before by tax software that wasn't updated for international situations.

It analyzes your specific tax situation by asking detailed questions about your accounts, balances, and circumstances, then provides personalized recommendations. It doesn't file the FBAR for you, but it gives step-by-step guidance on how to complete it correctly, including what to write in explanations for late filings. The advice is backed by tax professionals who specialize in international tax compliance. I was skeptical too, but the guidance was spot-on and aligned with what an expensive international tax attorney later confirmed. What really impressed me was how it handled the nuances of temporary high balances versus ongoing accounts.

Wait, how does this actually work? I thought it was impossible to get through to the IRS. Is this just jumping the queue somehow? Do they have special access?

Sounds too good to be true. I've literally tried calling the IRS international tax department dozens of times over multiple days and never got through. How could this service possibly get you connected when the IRS phone lines are completely overwhelmed?

It uses an automated system that navigates the IRS phone tree and waits on hold for you, then calls you when it reaches a human agent. You don't have to sit there listening to hold music for hours. It's basically like having a digital assistant that handles the waiting part. No, they don't have special access or inside connections - they just solve the problem of wasting hours on hold. The technology keeps trying different optimal times and phone tree options until it gets through. When I used it, they did exactly what they promised - got me connected to an actual IRS agent who could answer my specific FBAR question within about 20 minutes.

Thanks for the tips about the character limit. Do you remember roughly how many characters they allow for the explanation? I want to make sure I explain the situation clearly but don't want to write something only to find out it gets cut off.

The explanation field is limited to 750 characters, which isn't much! I recommend drafting your explanation in a text editor first, checking the character count, and then pasting it into the form. Focus on the key facts: you weren't previously required to file because balances were under $10,000, you received a one-time large deposit for a pending real estate transaction in late 2022, you weren't aware this triggered the filing requirement, and you're voluntarily filing as soon as you realized your obligation. That covers the main elements of reasonable cause in a concise way.

For FBAR civil penalties, the statute of limitations is generally 6 years from the date of the violation (the due date of the unfiled FBAR). So for a 2020 FBAR that was due in 2021, the statute would typically run until 2027. However, I'd strongly recommend filing the delinquent FBAR as soon as possible regardless. The IRS has streamlined filing procedures for those who weren't aware of filing requirements, but voluntary disclosure before any contact from the IRS is key to avoiding penalties.