IRS Removes Delinquent FBAR Safe Harbor — What It Means for Americans Abroad

July 2, 2026 - Participants include:   Virginia La Torre Jeker - @VLJeker   John Richardson - @ExpatriationLaw   On June 30, 2026 the IRS removed its "Delinquent FBAR Submission Procedures" page, ending the informal (guaranteed) penalty-free route for taxpayers who had only failed to file FBARs but otherwise reported and paid U.S. tax on foreign-account income. The change means taxpayers now face the penalty authority (not a mandate) found at 31 U.S.C. 5321 and examiner discretion found in the Internal Revenue Manual.  FBAR penalties are not automatic, but the safe-harbor promise found in the "Delinquent FBAR Submission Procedure" is gone, increasing uncertainty and the need for careful compliance and professional advice. Virginia La Torre Jeker and John Richardson discuss the possible implications of this change.