When Is It Too Late to Submit an IRS Voluntary Disclosure to Report Foreign Bank Accounts in 2026?
Posted in Offshore Account Update on September 16, 2026 | Share
While submitting a voluntary disclosure can mitigate the consequences of failing to report foreign bank accounts to the federal government, strict eligibility criteria (including filing deadlines) apply. If a taxpayer who is not eligible attempts to submit a voluntary disclosure, this could lead to consequences that could—and should—have been avoided.
Most U.S. taxpayers with foreign bank accounts must disclose these accounts to the federal government annually. Those who fail to do so can face steep penalties—including criminal penalties in some cases. While submitting a voluntary disclosure is one way for delinquent taxpayers to come into compliance, taxpayers must make informed decisions about when (and if) to file. Learn more from Washington, D.C. tax lawyer Kevin E. Thorn, Managing Partner of Thorn Law Group:
Who is Required to File a Report of Foreign Bank and Financial Accounts (FBAR)
The requirement to file a Report of Foreign Bank and Financial Accounts (FBAR) applies to U.S. taxpayers who have offshore accounts with an aggregate value greater than $10,000 at any point during the tax year. Individual and corporate taxpayers are both required to file, and the filing requirement applies to any taxpayer who “ha[s] an interest” in one or more offshore accounts that exceed the reporting threshold.
When Are FBARs Due?
All taxpayers must file their FBARs by April 15 each year. However, all taxpayers also receive an automatic six-month extension, making the final due date October 15.
What if I Missed the FBAR Filing Deadline?
If you missed the FBAR filing deadline for any tax year, it will be important to come into compliance proactively. Doing so can mitigate the consequences of a delinquent filing, while waiting until the IRS opens an audit or investigation can increase the risks.
Taxpayers with delinquent FBARs have two primary options for coming into compliance. Those who inadvertently failed to file may be eligible to submit a streamlined filing to the IRS, while those who willfully withheld information about their offshore accounts may need to submit a voluntary disclosure to IRS Criminal Investigation (IRS CI).
When Is It Too Late to Submit a Voluntary Disclosure?
Both streamlined filings and voluntary disclosures must be made “voluntarily.” This means that taxpayers must submit these filings before the IRS opens an audit or investigation. Once an audit or investigation is underway, any disclosures made during the process are no longer considered “voluntary,” and taxpayers are no longer eligible to receive benefits for coming forward on their own.
How Thorn Law Group Can Help
If you have concerns about FBAR compliance, we can help you make informed decisions about your next steps. We can also submit a streamlined filing or voluntary disclosure on your behalf and communicate with the IRS as warranted. Contact us to learn more.
Schedule a Confidential Initial Consultation with Washington D.C. Tax Lawyer Kevin E. Thorn
To discuss your situation with Washington D.C. tax lawyer Kevin E. Thorn, Managing Partner of Thorn Law Group, contact us today. Call 202-349-4033 or send us your contact information online to arrange a confidential initial consultation.
