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FBAR 2025 Update: Filing Requirements, Recent Cases, Deadlines, Extension, Penalty Resolution, Waiver Provisions

Who Must File, What Must Be Reported, Willful vs. Non-Willful Failures

A live 110-minute CPE webinar with interactive Q&A

This program is included with the Strafford CPE Pass. Click for more information.
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Thursday, December 4, 2025 (in 4 days)

12:00pm-1:50pm EST, 9:00am-10:50am PST

or call 1-800-926-7926
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This course will provide tax advisers with a practical guide to completing the Foreign Bank and Financial Accounts (FBAR) filing requirements. The panel will offer detailed instructions on completing and filing an FBAR, discuss recent IRS penalty enforcement actions for non-filing of foreign bank accounts, review recent cases, and describe extension provisions for the current filing year.

Description

Although the 11th Circuit Court recently ruled that certain FBAR penalties were excessive, even when willful, (Schwarzbaum, 24 F.4th 1355 (11th Cir. 2022)), the IRS continues to pursue these lucrative penalties. Foreign bank accounts remain a top priority for the IRS, including imposing penalties in the millions of dollars against taxpayers who do not timely file a complete Report of FBAR. While the form and filing requirements remain in place, FinCEN and the IRS have extended some filing deadline protections to benefit taxpayers required to disclose foreign-based financial account balances.

FBAR remains a complicated reporting obligation and the IRS will cross-reference FBAR information with other tax filings, as well as information disclosures from other sources such as foreign financial institutions. This makes failure to accurately report assets on the FBAR potentially very costly for U.S. taxpayers, even with the extension provisions of the new regulations.

Listen as our experienced panel provides a comprehensive guide to completing the FBAR forms.

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Outline

  1. What triggers FBAR filing requirements
    1. Entity ownership
    2. $10,000 threshold
    3. When are a company's officers personally responsible?
  2. Information to report on the FBAR vs. Form 8938
    1. Ownership accounts, accounts with signature authority, combined report accounts
    2. Form 8938 and associated IRS forms for foreign ownership/transactions
  3. Update on enforcement and new developments
    1. FBAR and Form 8938 penalties
    2. Willfulness standard and the non-willful certification
    3. Avenues and procedures
    4. Audits and examination
    5. Civil vs. criminal sanctions

Benefits

The panel will review these and other key issues:

  • When can corporate officers' stake in foreign accounts trigger reporting responsibilities?
  • What is the latest in the IRS and FinCEN enforcement activity?
  • What are the options for companies required to file an FBAR and have not?
  • How do Form 8938 filing requirements intersect with FBAR?

Faculty

Drabkin, Igor
Igor S. Drabkin
Tax Attorney & Principal
Holtz, Slavett & Drabkin

Mr. Drabkin represents tax clients in disputes with the IRS and state revenue authorities, both administratively...  |  Read More

Attend on December 4

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Cannot Attend December 4?

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CPE On-Demand

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BARBRI | Strafford

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The same expert-led professional development courses you know and love from Strafford are now part of BARBRI, the trusted global leader in legal education.

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