2026 FBAR Voluntary Disclosures: What Delinquent Taxpayers in New Jersey Need to Know

Failing to disclose foreign bank accounts to the federal government on time can lead to steep penalties—including criminal penalties in some cases. As a result, taxpayers behind on foreign bank account disclosures should work with experienced tax counsel to come into compliance before the IRS opens an audit or investigation.

U.S. taxpayers must disclose foreign bank accounts with an aggregate value greater than $10,000 at any point during the tax year. This disclosure is made using the Report of Foreign Bank and Financial Accounts (FBAR), which is due no later than October 15. Taxpayers who fail to file an FBAR by the deadline can face steep penalties, so it's critical to remedy delinquent FBAR filings promptly. Learn more from New Jersey tax lawyer Kevin E. Thorn, Managing Partner of Thorn Law Group:

What Should U.S. Taxpayers Do if They Failed to Timely File an FBAR?

Due to the steep penalties for failing to timely disclose offshore accounts to the federal government (which can include criminal penalties in some cases), taxpayers who have failed to timely file an FBAR should prioritize coming into compliance. Depending on the circumstances at hand, this may involve:

• Submitting a Streamlined Filing – Taxpayers who inadvertently failed to file an FBAR may be able to submit a streamlined filing to come into compliance and reduce the risk of IRS scrutiny related to their delinquency.
• Submitting a Voluntary Disclosure – Taxpayers who have willfully failed to file an FBAR may need to submit a voluntary disclosure to IRS Criminal Investigation (IRS CI) in order to eliminate their risk of facing criminal prosecution.

The IRS defines “willful” noncompliance broadly. As a result, taxpayers behind on FBAR filings should consult experienced tax counsel to make an informed decision about how best to proceed. Crucially, both options are available only if the IRS has not yet opened an audit or investigation.

What Are the Risks of Failing to Timely File an FBAR?

Failing to file an FBAR on time can have serious consequences. At a minimum, inadvertent FBAR noncompliance carries civil monetary penalties of up to $16,536 per violation (as of 2026). In cases involving willful noncompliance, taxpayers can face criminal charges carrying six-figure fines and the possibility of federal imprisonment.

How Thorn Law Group Can Help

If you need to come into compliance with the federal FBAR filing requirement for offshore accounts, we can help you take the necessary steps. We have extensive experience guiding taxpayers through streamlined filing and voluntary disclosure processes, as well as representing taxpayers in high-risk IRS audits and investigations. We can help you make informed and strategic decisions, and we can take action on your behalf immediately if necessary.

Schedule a Confidential Call with New Jersey Tax Lawyer Kevin E. Thorn

To speak with New Jersey tax lawyer Kevin E. Thorn, Managing Partner of Thorn Law Group, about your situation in confidence, contact us today. Call us at 201-842-7696 or tell us how we can reach you online to schedule a call as soon as possible.