Did You Miss the October 15 Deadline to File an FBAR in 2025?

Taxpayers who own offshore accounts with an aggregate value of $10,000 or more at any time during the calendar year are required to file a Report of Foreign Bank and Financial Accounts (FBAR) with the Financial Crimes Enforcement Network (FinCEN). FBAR filings are due on April 15, though all taxpayers receive an automatic six-month extension—making FBARs due no later than October 15 each year.

What do you need to know if you missed the October 15 FBAR deadline in 2025? Maryland offshore tax lawyer Kevin E. Thorn, Managing Partner of U.S. International Tax Advisors, explains.

Options for Resolving Delinquent FBARs in 2025

Even though taxpayers must file their FBARs with FinCEN, the IRS is responsible for enforcing taxpayers’ offshore account disclosure obligations. While the IRS uses audits and investigations to enforce compliance, it also offers two primary options for taxpayers to proactively resolve delinquent FBAR filings:

1. The IRS’ Streamlined Filing Compliance Procedures

Taxpayers who have inadvertently failed to file an FBAR in 2025 may be eligible to submit a “streamlined filing.” The IRS’ streamlined filing compliance procedures are available to taxpayers who have committed non-willful offshore account disclosure violations. Eligibility criteria apply, and if the IRS disputes a taxpayer’s certification of non-willfulness, it can reject the filing and open an audit or investigation.

2. IRS CI’s Voluntary Disclosure Practice

IRS Criminal Investigation’s (IRS CI) Voluntary Disclosure Practice provides a means for U.S. taxpayers to resolve willful violations of the law while limiting their exposure to criminal prosecution. While submitting a voluntary disclosure can be the best course of action in appropriate cases, here too, taxpayers with delinquent FBARs must be careful to ensure that their filings do not do more harm than good.

Taxpayers Who Need to File an FBAR May Also Need to File IRS Form 8938

Importantly, taxpayers who need to file an FBAR to disclose their offshore accounts may also need to file IRS Form 8938. While the FBAR applies to offshore accounts with an aggregate value of $10,000 or more, taxpayers living in the U.S. must file IRS Form 8938 if their “foreign financial assets” (which include offshore accounts) exceed the following thresholds:

• Unmarried or Married Filing Separately – Total value of more than $50,000 on the last day of the tax year or more than $75,000 at any time during the year.
• Married Filing Jointly – Total value of more than $100,000 on the last day of the tax year or more than $150,000 at any time during the year.

IRS Form 8938 is due when a taxpayer files his or her annual return. Similar to FBAR violations, IRS Form 8938 violations can trigger civil or criminal penalties, and streamlined filings and voluntary disclosures are potential options for coming into compliance.

Schedule a Confidential Consultation with Maryland Offshore Tax Lawyer Kevin E. Thorn

If you need to know more about the options for proactively resolving offshore account disclosure violations with the IRS, we encourage you to contact us promptly. Please call 240-235-5096 or contact us online to schedule a confidential consultation with Maryland offshore tax lawyer Kevin E. Thorn, Managing Partner of U.S. International Tax Advisors.