I reported the income but forgot the FBAR — what now?
That is the fact pattern the delinquent submission route exists for. Where the income from the accounts was reported and the only omission was the account report itself, there is a narrow way to file late with a reasonable-cause statement and no penalty. It rests on two things being genuinely true: no unreported income, and no examination under way. Those are not formalities. Before anything is filed, the returns for the years in question should be checked line by line against the account statements, because a single unreported interest credit takes the filing out of this route and into a different one.
What counts as reasonable cause for a late FBAR?
A statement that explains the omission, in terms of what actually happened rather than what sounds acceptable. It is written from the same material that proves it: when the account was opened, by whom, what the filer understood about reporting, what their return preparer was asked, and what changed to bring the omission to light. Vague regret is not reasonable cause and neither is a recital of the rule. Where the explanation is that nobody ever asked about foreign accounts, the engagement letters and questionnaires that show it are the evidence, and they belong with the statement.
Do I need the streamlined programme just for a missing FBAR?
Not necessarily, and that distinction is worth money. The disclosure programmes are built for filers with unreported income behind the unfiled reports. Where the income was on the return all along and the account report was simply missed, the delinquent submission route is the narrower and cheaper answer. The test is factual. Work through every year: if the income is fully reported and nothing has been opened against you, the narrow route is available. If either condition fails, filing under it is not a small error, so the checking has to come before the filing.
What is the FBAR filing threshold and where is it filed?
The report is required where the aggregate value of all your foreign financial accounts exceeded US$10,000 at any time during the calendar year; that threshold applies for the 2025 calendar year. Two features of it catch people. It is aggregate, so several small accounts can cross it together while none does alone, and it is measured at any point in the year rather than at year end, so a balance that passed through and left still counts. It is filed with FinCEN and not attached to your return, which is why a correctly filed return tells you nothing about whether the report was made.
Can I still file late if the IRS has already contacted me?
An examination already under way is one of the two conditions that closes the narrow route, so the answer depends on what the contact actually was. A notice about something unrelated is not the same as an examination touching these years, and the distinction has to be established from the correspondence rather than from memory of a phone call. Stop before filing anything and establish what has been opened, for which years, and on what basis. Filing into an open examination on the assumption that the route is available is the version of this that goes badly.
How many years of late FBARs should I file?
That is set by the route you are filing under rather than chosen, and it is one of the reasons the sequence matters more than the arithmetic. Pick the period first, in writing, and prepare every year in it together so the statement covers the same span as the filings. The related trap is filing one year to test the water. The route taken for the first year shapes what remains available for the years behind it, so a partial submission can close off the treatment the rest of them needed.
Do I have to declare my dual citizenship?
A tax return does not generally ask you to declare which passports you hold; it asks about residence, and in the US case it applies to citizens by definition. What does ask is your bank. Account-opening self-certification under FATCA and the Common Reporting Standard asks which countries you are a tax resident or citizen of, and the answer is reported onward to the tax authority. So the practical answer is that the information arrives either way. See FATCA reporting.
What is a foreign trust for US tax purposes?
A trust that is not a domestic trust — broadly, one that fails the tests looking at whether a US court can exercise primary supervision and whether US persons control the substantial decisions. The classification decides everything downstream: whether the settlor is taxed on the income as owner, how distributions to US beneficiaries are taxed, and which annual information returns are due. Many ordinary foreign arrangements, including some pension and education savings vehicles, land inside the definition. See Form 3520-A.
