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  • 1.  F-Bar

    Silver Most Valuable Member
    Posted 03-19-2019 16:01
    Have a client with Canadien funds who didn't file an F-Bar in past years. It's a matter of a few bank accounts that she wasn't aware that she had to file for. She wants to be in compliance.
    Is there any harm in filing 2017 late and should she file prior years and if so, how far back?

    Thank you

    Allfonso J. Mollica CPA

    Alfonso J. Mollica CPA, P.C.

    Thank you.

  • 2.  RE: F-Bar

    Posted 03-20-2019 09:15
    Please get an attorney experienced in these FBAR matters.  The IRS has many punitive, not just financial, arrows in their scabbard to put your TP at risk.  This is not an area you want to be a learning experience!

    Robert Gaines CPA
    Temple TX

  • 3.  RE: F-Bar

    Posted 03-21-2019 21:11



    They may be able file an international voluntary disclosure.    I use Blank Rome llp for my tax legal issue.  Joe Gulant is a partner and is extremely good.



    Best regards,
    Nick Puglisi
    Nicholas Puglisi, CPA, CFE, CFF
    PMG Certified Public Accountants, LLP

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  • 4.  RE: F-Bar

    Posted 03-20-2019 09:59
    ​Hi Alfonso,

    PLEASE DO NOT just file.
    If she just files she is opening herself up to many potential issues and problems

    1. Potential FBAR penalties of $10,000 per account up to 50% of the balance of each account for each year the account has been held.
    2. Depending on what the balance in each account is and what type of accounts these are, she may potentially have unreported income and a tax liability related to this income.
    3. These accounts could also have their own information reporting associated with them.  eg. 8621, 3520, 8938.....

    The clients full situation will need to be reviewed  before any filing decisions are made.

    I find the cleanest easiest way for her to file back years and become fully compliant with reduced risk of harsh penalties is through the Streamline program.  She would file 6 years of FBARs and amend the 3 most recent tax years.   You should ensure she does not have a 3520 filing requirement as this extension date has already past for 2018.  If this is the case this is considered late and the penalties are high.


    Linda Weingust
    Weingust Accounting & Taxation Inc.
    LaSalle ON - Canada

  • 5.  RE: F-Bar

    Silver Most Valuable Member
    Posted 03-20-2019 10:37
    Thank you
    no idea of the complexity
    Don't believe accounts are now than $30000 US

    Alfonso Mollica
    Mollica Taxes & Accounting
    Levittown NY
    516 597-4991

  • 6.  RE: F-Bar

    Posted 03-20-2019 22:18
    I had the same issue last season - I spoke with some practitioners at the NATP conference that work with many FBAR clients and they recommended at least 3, but preferably 6 years, if the balance requirements were met that far back.

    Nicole Odeh
    The Small Business Accounting Solution Inc

    A Profit First Adviser Company - let us help YOU put Profit First

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  • 7.  RE: F-Bar

    Bronze Most Valuable Member
    Posted 03-21-2019 08:03
    Please listen to the advice of others posted here. Especially if there are significant balances in these accounts, there may be criminal charges for your client as well. Amnesty is over. Seek legal advice.

    Irene Wachsler, CPA
    Tobolsky & Wachsler CPAs LLC
    Assisted 150+ productions