FBAR Penalty Estimator 2026

Civil willful vs. non-willful FBAR penalties. Bittner v. US (2023) Supreme Court ruling. Reasonable cause defense. Streamlined Procedures vs. Voluntary Disclosure. FinCEN 114. 31 USC 5314.
31 USC 5314 - FBAR requirement31 USC 5321 - civil penaltiesBittner v. US (2023)Streamlined vs. VDP
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FBAR Violation Details

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FBAR penalties are among the harshest in US tax law. Civil willful penalties can reach $100,000+ per violation per year (adjusted for inflation). Criminal willful violations carry up to 5 years imprisonment. This estimator covers civil penalties only. If criminal exposure is possible, engage counsel immediately before making any disclosures.
Number of calendar years for which FBAR was not filed when required. 6-year statute of limitations for civil FBAR penalties (31 USC 5321(b)(1)).
After Bittner v. US (2023), non-willful penalties apply per form (one per year), not per account. Willful penalties still apply per account. This field primarily affects willful penalty estimates.
Highest aggregate balance across all unreported accounts in any single year. Willful penalty ceiling is 50% of highest balance per violation. 31 USC 5321(a)(5)(C).
Reasonable cause eliminates non-willful penalty if taxpayer acted in good faith. Does NOT eliminate willful penalty. 31 USC 5321(a)(5)(B)(ii).
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Penalty Estimates

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FBAR Filing Checker FBAR Penalties Guide Streamlined Procedures Checker CFC / Form 5471 All Tools
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