Will filing my first FBAR this year trigger a review of my previous unfiled FBAR obligations?
Title: Will filing my first FBAR this year trigger a review of my previous unfiled FBAR obligations? 1 I immigrated to the United States about 5 years ago and have been diligently doing my taxes through TurboTax since then. Recently, I discovered that I should have been reporting my foreign bank accounts since they exceed $10,000 in total. I honestly had no idea about the FBAR (FinCEN Form 114) requirement until a colleague mentioned it casually during lunch. My foreign accounts are in my home country and collectively worth around $17,500. I've maintained these accounts since before moving to the US, and I've been using them occasionally to send money to family back home. The accounts have always been declared and taxed in my home country. I'm planning to submit an FBAR for the first time with my 2025 taxes, but I'm worried that filing now might raise red flags with the IRS or FinCEN about my previous years. I'm concerned that this could trigger an investigation into my past FBAR filing obligations and potentially result in massive penalties. From what I've read online, these penalties can be extremely harsh. Does anyone know if filing an FBAR for the first time will automatically prompt a review of previous years when I should have filed? Should I instead look into the voluntary disclosure programs? I'm trying to do the right thing going forward but am worried about the consequences of my previous unintentional non-compliance.
21 comments


Natasha Kuznetsova
15 You're right to address this situation now rather than continuing to not file. The FBAR requirement catches many immigrants by surprise. The good news is that the IRS and FinCEN distinguish between willful and non-willful violations. From what you've described, yours would likely be considered non-willful since you genuinely didn't know about the requirement. For non-willful violations, they tend to be much more lenient. While filing your first FBAR doesn't automatically trigger an investigation into past years, it does potentially put you on their radar. The safest approach would be to use the IRS's Streamlined Filing Compliance Procedures, which is specifically designed for taxpayers who non-willfully failed to report foreign financial assets and pay taxes on income from those assets. This program allows you to become compliant while potentially avoiding penalties. The streamlined procedures require you to file FBARs for the last 6 years and amended tax returns for the last 3 years if needed, along with a statement explaining that your failure to file was non-willful. It's a much better option than simply starting to file now and hoping nobody notices the gap.
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Natasha Kuznetsova
•7 Thanks for this information. I've heard about the Streamlined program but wasn't sure if it applied to my situation. Do you know if I need to hire a tax attorney to go through this process, or can I handle it myself? Also, will using the Streamlined program likely result in me owing additional taxes beyond what I've already paid?
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Natasha Kuznetsova
•15 You can technically complete the Streamlined Filing Compliance Procedures yourself, but many people do seek professional help because of the complexity and what's at stake. The forms aren't particularly difficult, but ensuring your non-willful statement is properly written is crucial since that's what protects you from more severe penalties. As for additional taxes, that depends on whether you properly reported all income from those foreign accounts on your US tax returns. If you did report all the income but just missed the FBAR filing, you might not owe additional taxes. If you didn't report income like interest or dividends from those accounts, then yes, you would need to pay those taxes plus interest as part of the process.
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Natasha Kuznetsova
8 I went through almost the exact same situation last year. After discovering I needed to file FBARs, I was panicking about potential penalties. I tried calling the IRS but couldn't get through to anyone who could help with international tax questions. Then I found this service called taxr.ai (https://taxr.ai) that specifically helps with international tax compliance issues. They have specialists who review your foreign account documentation and help determine the best compliance approach based on your specific situation. What I appreciated most was that they handled my Streamlined Filing Compliance Procedure and made sure my non-willful statement was properly documented. They explained that simply filing a current FBAR without addressing past non-compliance could potentially cause more issues down the road.
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Natasha Kuznetsova
•12 Did they help with just the FBAR forms or did they also handle the amended tax returns? I'm in a similar situation but most of my foreign income was already reported, I just didn't know about the separate FBAR filing requirement.
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Natasha Kuznetsova
•19 I'm skeptical about these types of services. How much did it end up costing? And did they actually connect you with real tax professionals or is it just some automated system? My situation with foreign accounts is pretty complicated with accounts in multiple countries.
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Natasha Kuznetsova
•8 They helped with both the FBAR forms and the amended returns. In my case, I had already reported most of my foreign income too, but there were some interest payments I had missed. They handled everything as a package which made it much simpler. Regarding your questions about the service, they actually connect you with real tax professionals who specialize in international tax issues. It's not just an automated system - you get actual experts reviewing your documents. My situation also involved accounts in multiple countries (Japan and Germany), and they were able to handle the complexity without issues.
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Natasha Kuznetsova
12 Just wanted to update after taking the advice about taxr.ai from this thread. I was initially worried about handling my FBAR situation, but decided to give them a try. They reviewed all my foreign account statements and found that I qualified for a simplified streamlined filing. The specialist pointed out that simply filing a current FBAR without addressing the past years would have been risky. They helped me prepare the last 6 years of FBARs and reviewed my tax returns to ensure all foreign income was properly reported. What really impressed me was how they documented everything to demonstrate my non-willful status, which apparently is critical if there's ever any question from the IRS. The whole process was much less stressful than I expected, and I'm now fully compliant without having to worry about looking over my shoulder!
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Natasha Kuznetsova
3 I had a similar issue with missing FBARs a couple years ago. When I finally discovered the requirement, I was totally stressed trying to get through to someone at the IRS to discuss my options. I must have called 20+ times and either got disconnected or was on hold for hours. A friend recommended I try Claimyr (https://claimyr.com) to actually get through to an IRS agent. I was skeptical but checked out their demo video (https://youtu.be/_kiP6q8DX5c) and decided to give it a shot. The service basically waits on hold with the IRS for you, then calls you when an actual human agent is on the line. I finally got to speak with an IRS representative who walked me through my options for the unfiled FBARs. Having that conversation made a huge difference in my approach and ultimately saved me from making mistakes that could have triggered penalties.
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Natasha Kuznetsova
•6 How does this actually work? Do they somehow have a special line to the IRS or something? I've been trying to reach someone about my own FBAR questions for weeks with no luck.
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Natasha Kuznetsova
•19 This sounds too good to be true. The IRS wait times are legendary. I've literally spent entire days trying to get through. You're saying this service somehow jumps the queue? I find it hard to believe they can do something individuals can't do themselves.
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Natasha Kuznetsova
•3 It's not a special line to the IRS - they basically use technology to wait on hold for you. When they reach a human agent, they call you and connect you to the call. It's like having someone else do the waiting for you. There's definitely no queue jumping - you still wait your turn, but their system handles the hold time instead of you having to sit there listening to the hold music for hours. For my FBAR questions, I needed to speak with someone in the international tax department which had particularly long wait times. Their system called me back about 3 hours later when they finally got through to an agent.
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Natasha Kuznetsova
19 I want to follow up on my skeptical comment earlier. After struggling to get IRS help with my FBAR situation for weeks, I finally tried Claimyr out of desperation. I'm shocked to admit it actually worked! I had been trying to reach the international tax department at the IRS for specific guidance on accounts from multiple countries. Using their service, I got a call back about 2 hours later with an actual IRS agent on the line who specialized in international reporting. The agent walked me through the Streamlined Filing Compliance Procedures and gave me specific advice for my situation. He confirmed that simply starting to file FBARs now without addressing past years could potentially create bigger problems down the road. Having a real conversation with the IRS saved me from making a serious mistake in how I approached my compliance. I'm now working through the proper procedures and feel much more confident about resolving this correctly.
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Natasha Kuznetsova
22 One important thing nobody has mentioned yet: make sure you're using the correct exchange rates when reporting your foreign account balances on the FBAR. The IRS expects you to use the Treasury's Financial Management Service rate for the end of the calendar year (December 31). Using incorrect exchange rates is a common mistake that can cause problems, especially if it makes the difference between being over or under the $10,000 threshold. You can find the official rates on the Treasury's website. Also, remember the FBAR is filed separately from your tax return through FinCEN's BSA E-Filing System. The deadline technically aligns with Tax Day, but there's an automatic extension to October for FBARs.
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Natasha Kuznetsova
•4 Do you need to file an FBAR if you only briefly had over $10,000 in foreign accounts? I had about $12,000 in a foreign account for just 2 weeks while I was in the process of transferring money to the US when I moved here, but the balance was under $10,000 for the rest of the year.
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Natasha Kuznetsova
•22 Yes, you do need to file an FBAR in that situation. The $10,000 threshold applies to the maximum balance at any point during the year, not just at year-end. So even if you had over $10,000 for just two weeks, you still have an FBAR filing requirement for that entire year. This is a common misunderstanding that trips up a lot of people. The FBAR rules look at the highest balance at any point during the calendar year, regardless of how brief that period might have been.
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Natasha Kuznetsova
5 I experienced almost the exact same situation after moving from Australia. I didn't file FBARs for 3 years because I had no idea they existed. When I learned about them, I used the Streamlined Foreign Offshore Procedures. The key thing that helped me was writing a really clear statement explaining why my failure to file was non-willful. I explained how tax preparation in Australia works differently, how I had always been compliant in my home country, and that I used consumer tax software that didn't prominently ask about foreign accounts. If you've been reporting all income from these accounts on your US tax returns and just missed the FBAR filing, that helps demonstrate good faith too. The IRS seems much more concerned about hidden income than about missing informational forms when the income was properly reported.
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Natasha Kuznetsova
•9 This is so helpful. I'm from Australia too and just realized I've missed filing FBARs for my superannuation accounts. Did you include your super in your FBAR filings? I've read conflicting information about whether retirement accounts need to be included.
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Lucas Lindsey
•Australian superannuation accounts are generally not required to be reported on FBARs if you don't have signature authority or financial interest in the underlying investments. Most super funds are considered employer-sponsored retirement plans where you can't directly control the individual investments. However, if you have a self-managed super fund (SMSF) where you do have control over the investments and accounts, then those would likely need to be reported. The key test is whether you have signature authority or other financial interest in the foreign accounts. I didn't include my regular super in my FBAR filings after consulting with a tax professional, but this is definitely one of those areas where the rules can be complex. Given that you're going through the Streamlined procedures anyway, it might be worth getting professional guidance on the super question to make sure you're handling it correctly.
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Freya Andersen
I'm in a very similar situation - been in the US for 4 years and just discovered FBAR requirements. Like you, I've been diligent about my regular tax filings but had no idea about these foreign account reporting obligations. From reading through all these responses, it sounds like the Streamlined Filing Compliance Procedures are definitely the way to go rather than just starting to file FBARs now. The fact that multiple people have mentioned that simply filing current FBARs without addressing past years could create bigger problems is really concerning. I'm particularly worried because my foreign accounts have fluctuated above and below the $10,000 threshold over the years, so I'm not even sure which years I should have filed. Has anyone dealt with a situation where you're not entirely certain which years triggered the filing requirement? I kept good records of my account balances, but I'm realizing I need to go back and calculate the maximum balances for each year using the correct Treasury exchange rates. The suggestions about getting professional help are making a lot of sense to me now. This seems too complex and high-stakes to risk getting wrong on my own.
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Amina Sow
•You're absolutely right to be cautious about this. The fluctuating balances make your situation more complex because you'll need to determine the exact maximum balance for each calendar year using the Treasury exchange rates that were in effect on December 31st of each year. I'd strongly recommend keeping detailed records of when your accounts crossed the $10,000 threshold. Even if it was just for a few days in a given year, that still triggers the filing requirement for that entire year. The IRS doesn't care if you were over the threshold for just a week - the maximum balance test applies to any point during the calendar year. Given the complexity of your situation with fluctuating balances across multiple years, professional help really does seem like the smart move. The Streamlined procedures require you to be very precise about which years you're addressing, and getting that wrong could cause more problems than it solves. Better to invest in getting it done correctly the first time than to risk having to deal with complications later.
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