FinCEN revises beneficial ownership information reporting requirement
FinCEN issued a final rule revising BOI reporting. Business owners should confirm whether their entities still have a filing obligation.
Source: Federal Register

NRIs · Expats · Streamlined procedures
Many US taxpayers of Indian origin, and expats from other countries, keep NRE and NRO accounts, fixed deposits, mutual funds or insurance policies back home without knowing they had to report them. We help you catch up correctly, usually through the IRS Streamlined Filing Compliance Procedures.
Serving United States, India, Worldwide.
What we handle
US citizens, green card holders and US tax residents must report worldwide income, including interest on Indian fixed deposits, and file an FBAR when foreign accounts together exceed $10,000 at any time in the year. Form 8938 may also be required, and Indian mutual funds are usually passive foreign investment companies (PFICs) that need Form 8621.
If you missed these filings without willful intent, the Streamlined procedures let you file three years of returns and six years of FBARs. Residents of the US use the domestic procedure (SDOP), which carries a 5% penalty on the highest year-end value of the covered foreign assets; those who meet the non-residency test use the foreign procedure (SFOP), with no offshore penalty.
Speak with an advisorWhere we help
Accounts in India kept open after moving, never reported on US returns.
Expats who meet the 330-day non-residency test and may qualify for SFOP.
Assets inherited from parents abroad that created new reporting.
Planning for residency changes, exit and continuing US filing duties.
Our approach
Every foreign account, deposit, fund and policy, with year-end balances for six years.
SDOP, SFOP or another approach, explained in writing with the expected cost.
Three years of returns, six years of FBARs, PFIC calculations and the certification.
Mail the submission, file FBARs electronically, then handle each new year.
Questions
If your question isn't here, call (703) 880-8412 and you'll reach a person.
If you are a US citizen, green card holder or US tax resident, yes. Interest is taxable in the US even when it is tax-free in India, and the accounts count toward the $10,000 FBAR threshold and the Form 8938 thresholds.
SDOP is for US residents and carries a 5% miscellaneous offshore penalty. SFOP is for taxpayers who, in at least one of the last three years, were outside the US for at least 330 full days and had no US abode (for citizens and green card holders), or did not meet the substantial presence test (for others). SFOP has no offshore penalty.
Usually they are PFICs, which require Form 8621 and can be taxed under punitive default rules. Under the Streamlined procedures we compute the PFIC tax for the three return years and recommend elections for the future.
The IRS describes non-willful conduct as negligence, inadvertence, mistake or a good-faith misunderstanding of the law. You must explain the specific reasons in your certification, and a generic statement can lead to closer review.
Generally not if you are already under IRS civil examination for any year, or under criminal investigation. That is why acting before any IRS contact matters.
The IRS retired its Delinquent FBAR Submission Procedures in July 2026. Whether a stand-alone late FBAR filing with a reasonable-cause statement is enough depends on whether any income went unreported, so we review your facts before recommending a path.
Latest updates
FinCEN issued a final rule revising BOI reporting. Business owners should confirm whether their entities still have a filing obligation.
Source: Federal Register
The IRS took down the page that described penalty relief for late FBARs when all income had been reported. Get advice on reasonable cause or the Streamlined procedures before filing late FBARs.
Source: EY Tax News
Related
FBAR filing for US persons with foreign bank and financial accounts: who must file FinCEN Form 114, the $10,000 threshold, deadlines, penalties after Bittner v.
Learn moreInternational taxForm 8938 under FATCA (IRC 6038D): who must file, filing thresholds for residents and expats, how it differs from the FBAR, penalties and the extended statute of limitations.
Learn moreInternational taxForm 5471 for US owners, officers and directors of foreign corporations, including Indian private limited companies: filing categories, Subpart F and section 951A income, section 962 elections, penalties and Farhy.
Learn moreInternational taxForm 8865 for US persons with interests in foreign partnerships and LLPs: filing categories, contributions and transfers, penalties and how to fix missed years.
Learn moreInternational taxForm 3520 for gifts and inheritances from parents and relatives abroad, foreign trust distributions and Form 3520-A: thresholds, deadlines, penalties and how to file late.
Learn moreInternational taxUS tax returns for Americans and green card holders living abroad: the foreign earned income exclusion, foreign tax credit, FBAR and Form 8938, state residency and the Streamlined Foreign Offshore Procedures.
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