FBAR Please Help
Jul 3rd 2025 | 4:06 am
#16
Thread Starter
Forum Regular
Joined: Jun 2020
Posts: 96
Re: FBAR Please Help
Again, thank you. I'll find a CPA but just so I proceed with knowledge, I would be grateful for some clarifications (forgive the lack of financial acumen):I will find a CPA—I have read each post and downloaded the forms (yet to read) and I have a few clarification questions if that is okay:
1. I may have misunderstood the statute of limitations given advice above; to clarify—will I need to submit 1040 for the past 3 years & FBAR for 6 years or each for as long as I have been a permanent resident?
2. Given that foreign income should have been declared on each 1040, a CPA will need access to previous 1040 submissions (is this just for the past 3 tax years?) and any foreign income will complicate the overall tax submission (eg., potentially changing tax brackets)? Seems potentially quite tricky for me as I use a tax preparer.
3. Does one submit three years of individual 8939s etc or do retrospective tax submissions go on one form?
4. How is the SDO calculated—is it 5% on assets for each year (for three years?) and then added together for a total sum? Or it it "one-off"?
5. To calculate assets do you use the end of tax year (31/12) for each submission?
6. Is the “reasonable cause†a separate form? Is it submitted separately for FBAR and for IRS?
7. Does one attach copies of their UK assets (eg., bank statements) or just fill in the appropriate numbers?
1. I may have misunderstood the statute of limitations given advice above; to clarify—will I need to submit 1040 for the past 3 years & FBAR for 6 years or each for as long as I have been a permanent resident?
2. Given that foreign income should have been declared on each 1040, a CPA will need access to previous 1040 submissions (is this just for the past 3 tax years?) and any foreign income will complicate the overall tax submission (eg., potentially changing tax brackets)? Seems potentially quite tricky for me as I use a tax preparer.
3. Does one submit three years of individual 8939s etc or do retrospective tax submissions go on one form?
4. How is the SDO calculated—is it 5% on assets for each year (for three years?) and then added together for a total sum? Or it it "one-off"?
5. To calculate assets do you use the end of tax year (31/12) for each submission?
6. Is the “reasonable cause†a separate form? Is it submitted separately for FBAR and for IRS?
7. Does one attach copies of their UK assets (eg., bank statements) or just fill in the appropriate numbers?
Jul 3rd 2025 | 5:48 am
#18
Furby
Joined: Apr 2016
Posts: 1,188
From: St. Louis, MO.
Re: FBAR Please Help
You are not in the dark. This and other forums can help you. Many years ago, as with many others, I knew nothing about these requirements and had to start from scratch without any advice whatsoever and to add insult to injury the penalty back then was 25% versus 5% now. You are in a much better position. It sounds like you may have a substantial amount of undeclared income and if so you need to come into compliance as quickly as you can. Rather than focusing upon what may or not be unfair you need to move forward. Start contacting CPAs in you area, if they cannot help ask them for recommendations. You have to start somewhere.
Jul 3rd 2025 | 6:02 am
#19
Furby
Joined: Apr 2016
Posts: 1,188
From: St. Louis, MO.
Re: FBAR Please Help
1. I may have misunderstood the statute of limitations given advice above; to clarify—will I need to submit 1040 for the past 3 years & FBAR for 6 years or each for as long as I have been a permanent resident? Yes, for each year that you should have originally submitted these forms, up to 3 years for Form 8938 on an amended tax return and up to 6 years for FBAR.
2. Given that foreign income should have been declared on each 1040, a CPA will need access to previous 1040 submissions (is this just for the past 3 tax years?) and any foreign income will complicate the overall tax submission (eg., potentially changing tax brackets)? Seems potentially quite tricky for me as I use a tax preparer. Yes. 1040s are submitted for the prior 3 years to include all foreign income and that may well push you into a higher tax bracket. It is not tricky, fairly straightforward really but it will likely increase your tax liability and result in tax due.
3. Does one submit three years of individual 8939s etc or do retrospective tax submissions go on one form? An amended return must be prepared for each of the prior 3 years and the relevant Form 8938 attached to each of those returns.
4. How is the SDO calculated—is it 5% on assets for each year (for three years?) and then added together for a total sum? Or it it "one-off"? The penalty is calculated as 5% of the highest annual aggregate balance for the years in question. To that extent it is a one time payment. They will look at the balances for all years in question and take 5% of the single year that has the highest balance.
5. To calculate assets do you use the end of tax year (31/12) for each submission? It is the highest balance at any time throughout the year translated into USD using the treasury exchange rate on 12/31 of the relevant year,
6. Is the “reasonable cause†a separate form? Is it submitted separately for FBAR and for IRS? The reasonable cause statement is supplied with each filing. So, yes, separate for FBAR and Form 8939 since they are independent filings.
7. Does one attach copies of their UK assets (eg., bank statements) or just fill in the appropriate numbers? Just supply the numbers but you are required to maintain documentation of how you derived those numbers.
2. Given that foreign income should have been declared on each 1040, a CPA will need access to previous 1040 submissions (is this just for the past 3 tax years?) and any foreign income will complicate the overall tax submission (eg., potentially changing tax brackets)? Seems potentially quite tricky for me as I use a tax preparer. Yes. 1040s are submitted for the prior 3 years to include all foreign income and that may well push you into a higher tax bracket. It is not tricky, fairly straightforward really but it will likely increase your tax liability and result in tax due.
3. Does one submit three years of individual 8939s etc or do retrospective tax submissions go on one form? An amended return must be prepared for each of the prior 3 years and the relevant Form 8938 attached to each of those returns.
4. How is the SDO calculated—is it 5% on assets for each year (for three years?) and then added together for a total sum? Or it it "one-off"? The penalty is calculated as 5% of the highest annual aggregate balance for the years in question. To that extent it is a one time payment. They will look at the balances for all years in question and take 5% of the single year that has the highest balance.
5. To calculate assets do you use the end of tax year (31/12) for each submission? It is the highest balance at any time throughout the year translated into USD using the treasury exchange rate on 12/31 of the relevant year,
6. Is the “reasonable cause†a separate form? Is it submitted separately for FBAR and for IRS? The reasonable cause statement is supplied with each filing. So, yes, separate for FBAR and Form 8939 since they are independent filings.
7. Does one attach copies of their UK assets (eg., bank statements) or just fill in the appropriate numbers? Just supply the numbers but you are required to maintain documentation of how you derived those numbers.
Last edited by Glasgow Girl; Jul 3rd 2025 at 6:05 am.
Jul 3rd 2025 | 6:03 am
#20
Thread Starter
Forum Regular
Joined: Jun 2020
Posts: 96
Re: FBAR Please Help
You are not in the dark. This and other forums can help you. Many years ago, as with many others, I knew nothing about these requirements and had to start from scratch without any advice whatsoever and to add insult to injury the penalty back then was 25% versus 5% now. You are in a much better position. It sounds like you may have a substantial amount of undeclared income and if so you need to come into compliance as quickly as you can. Rather than focusing upon what may or not be unfair you need to move forward. Start contacting CPAs in you area, if they cannot help ask them for recommendations. You have to start somewhere.
I am out of the USA for the next month and feel cut off. I have worked hard all year and was expecting a break. Instead I am panicking over this.
I only have Whatsapp so I cannot just call around, otherwise I would. The CPAs I google all seem to be like the lawyer I contacted--sponsored big box and big smiles and I have no contacts to help with recommendations. It is very hard to find a trustworthy CPA or lawyer just like that.
Last edited by Streetlegal; Jul 3rd 2025 at 6:06 am.
Jul 3rd 2025 | 6:06 am
#21
Forum Regular
Joined: Feb 2024
Posts: 151
From: Scotland
Re: FBAR Please Help
I think you mentioned in a previous post that you already use a tax preparer so IF you trust their judgement, you might ask them for recommendations. If you already work with a financial adviser that you trust, they might have recommendations. If you're working, you might ask colleagues (they don't need to know why.) You are under no obligation to use anyone that anyone recommends, you just need to get started on your search.
Jul 3rd 2025 | 6:11 am
#22
Thread Starter
Forum Regular
Joined: Jun 2020
Posts: 96
Re: FBAR Please Help
I think you mentioned in a previous post that you already use a tax preparer so IF you trust their judgement, you might ask them for recommendations. If you already work with a financial adviser that you trust, they might have recommendations. If you're working, you might ask colleagues (they don't need to know why.) You are under no obligation to use anyone that anyone recommends, you just need to get started on your search.
Does it matter if the CPA is in my location of the USA or not?
Jul 3rd 2025 | 6:20 am
#23
BE Forum Addict
Joined: Aug 2013
Posts: 2,218
From: Athens GA
Re: FBAR Please Help
However, as others have said, many have found themselves in your situation and resolved it relatively easily.
Jul 3rd 2025 | 6:29 am
#24
Thread Starter
Forum Regular
Joined: Jun 2020
Posts: 96
Re: FBAR Please Help
No, my tax preparer is part of a big box firm and nothing of this sort was ever mentioned, possibly because I transitioned from an H1B to a green card and no one gave pause to any change in my status.
Jul 3rd 2025 | 7:22 am
#25
Forum Regular
Joined: Feb 2024
Posts: 151
From: Scotland
Re: FBAR Please Help
I personally don't think it matters where your CPA is located. Prior to my move back to the UK from Texas, I was working with someone in Kansas City MO who I had been referred to. Most firms these days seem to be set up for virtual meetings, have online portals to share documents etc. If you feel like you absolutely need to be doing something while you are out of the US, maybe you can start a shortlist of companies to call when you get back, send messages to family/friends/colleagues asking if anyone has a solid CPA etc?
Jul 3rd 2025 | 7:32 am
#26
Thread Starter
Forum Regular
Joined: Jun 2020
Posts: 96
Re: FBAR Please Help
Thank you, everyone! I am using Yelp to compile a list of possible CPAs near where I reside in the States. Google just comes up with "sponsored" ads and I no longer trust these. I just wish I was in the States so I could just phone them--so frustrating. My tax preparer emailed me and had no recommendation 
.
.
Jul 3rd 2025 | 8:03 am
#27
Joined: Dec 2001
Posts: 53,356
From: Dixie, ex UK
Re: FBAR Please Help
Last edited by Pulaski; Jul 3rd 2025 at 8:05 am.
Jul 3rd 2025 | 8:05 am
#28
Thread Starter
Forum Regular
Joined: Jun 2020
Posts: 96
Re: FBAR Please Help
You can search here for a registered tax preparer registered with the IRS, and select "CPA" as a filter. Unfortunately there are no links to the preparer's own web site, so you'll need to go to Google to find them. Then you can verify the good standing of any CPA that you're interested in using here.
Last edited by Streetlegal; Jul 3rd 2025 at 8:15 am.
Jul 3rd 2025 | 9:32 am
#29
Thread Starter
Forum Regular
Joined: Jun 2020
Posts: 96
Re: FBAR Please Help
Every CPA: sponsored ad, sponsored ad, sponsored, ad, Indian. And you say it is easy to find a CPA??? Truth is if you are not in the know you are completely stranded. Why is there no list of decent human beings ordinary people can use? Utter madness that this is all so utterly arbitrary.
Why is it no one can recommend a CPA if you think there are so many decent ones?
Why is it no one can recommend a CPA if you think there are so many decent ones?
Last edited by Streetlegal; Jul 3rd 2025 at 9:38 am.
Jul 3rd 2025 | 9:38 am
#30
Joined: Dec 2001
Posts: 53,356
From: Dixie, ex UK
Re: FBAR Please Help
Every CPA: sponsored ad, sponsored ad, sponsored, ad, Indian. And you say it is easy to find a CPA?? Truth is if you are not in the know you are completely stranded. Why is there no list of decent human beings ordinary people can use? Utter madness that this is all so utterly arbitrary.
If you used the link I posted, it's just a list of names from the IRS, where are you seeing all these sponsored links?
You did filter your search on the IRS site for "CPA", didn't you?
Last edited by Pulaski; Jul 3rd 2025 at 9:45 am.
