Hi everyone, I would appreciate any help with a tax issue. For the past 32 years I have filed my taxes here in the US & have always gone to a professional accountant. I give him my details, answer any questions, pay the fee & he files my taxes with the IRS. Today I used a different accountant & he asked me if I had any foreign bank accounts & I said yes but that I had never been asked that before & was told that I should have been reporting this every year. He then said that he could re-submit previous years filings for me, for a fee naturally. Before I consent to his filing the previous tax returns showing the IRS that I had a foreign bank account should I reach out to my previous accountant and explain the situation to him in the hope that he will re-submit my returns as opposed to my paying what I think will be a substantial fee for my new accountant to file? As I say, any help would be greatly appreciated, thanks.

I think your previous tax preparer must have been under the allusion that you had no foreign bank accounts to not ask because he has to answer those specific questions in part 3 of Schedule B every single year. (Schedule B is where interest is reported). All the tax prep software specifically asks if they have foreign bank accounts and if the total sum is over $10k.

I would check your Schedule B first then ask the previous preparer why he completed your returns and said you didn’t have any foreign bank accounts.

Thanks for your response durhamlad. I have had a number of different accountants over the last 32 years & not one has thought to ask me about foreign accounts. For most of that time there was less than $10,000 in the accounts, maybe the last 10 years has there been more in the accounts. Do you know how far back the IRS will look at my foreign accounts as I only have tax returns going back 5 years? Also do you know the financial implications in terms of fines & late fees?
This is causing me a lot of worry when I’m dealing with the issues & cost involved with returning home. But, it’s an issue that I have to deal with & reaching out to people on here is a great help.

The IRS is only interested the reporting of accounts due to FATCA which are way higher thresholds than the FBAR reports which go to the Treasury.

If it has only been 2 or 3 years for accounts over $10k I would simply file 2 back years plus this last year 2021.

FBAR reports are only done online and for each filing you can give a year and indicate why it is late.

https://www.fincen.gov/

Thank you for the link durham lad. My mind is a lot more at ease after reading that, fines for “willful” as opposed to “non-willful” non reporting are vastly different. Also, I’m hoping I only have to resubmit tax returns for the last 5 years, fingers crossed. Once again, thanks for your help.

If you are below the FATCA thresholds for reporting and therefore have no extra forms to file then I’m not sure that filing corrected tax returns is necessary. You can take the following questionnaire on the IRS website:
https://www.irs.gov/help/ita/should-...amended-return

Basically, if nothing has changed in the tax calculation and it is simply an honest mistake in failing to mark the box in section III of Schedule B stating that you have foreign accounts then it is a waste of time and effort by IRS to process the return. You are going to be reporting those accounts via FBAR reports anyway.

further info below:
https://www.irs.gov/taxtopics/tc308

I've missed filing my FBAR for 2019 and 2020 - completely forgot about it with Covid going on (had it and now have long Covid) and kids back and forth to uni. I'm about to file my 2021 return and do my FBAR..should I back file 2019 and 2020 and apologise citing the pandemic and my reason for my delayed filing?

Yes. When filing there is a place to indicate the year and also the reason it is being filed late so I would submit 2019, and 2020, then 2021. It should be no problem, it must happen often.

Thanks DL - Hopefully they won't issue any penalty or fine. Have you heard of that being the case in this kind of circumstance? I'm under the FACTA filing requirement just had missed doing the FBAR...

This has been discussed before here and another expat forum I frequent. No one has ever heard of fines being imposed because of individuals missing FBAR deadlines or completely failing to file FBAR reports.

Thank you so much DL!! I can sleep much better knowing that.