Part 2 - IRS Removes Delinquent FBAR Procedure — What It Means for Americans Abroad

July 17, 2026 - Participants include: Virginia La Torre Jeker - @VLJeker John Richardson - @ExpatriationLaw   On June 30, 2026 the IRS removed the "Delinquent FBAR Submission Procedures" from its site. This ended the "FBAR Safe Harbour" that allowed for the (possible) filing of lates FBARs without penalty. This was discussed in the following two blog posts by John Richardson and Virginia La Torre Jeker. https://citizenshipsolutions.ca/2026/07/02/irs-ends-delinquent-fbar-submission-procedures-leaving-no-guaranteed-penalty-free-option/ https://www.forbes.com/sites/virginialatorrejeker/2026/07/02/irs-quietly-ends-penalty-free-fbar-filing-procedure-whats-next/ In addition we did an initial podcast on July 2, 2026 giving our initial impressions. https://prep.podbean.com/e/irs-removes-delinquent-fbar-safe-harbor-%e2%80%94-what-it-means-for-americans-abroad/   ___________________________   Today, on July 17, 2026 Virginia and John shared our additional thoughts in this podcast. This podcast -as a follow up - is Part 2.   "John Richardson speaks with U.S. tax lawyer Virginia La Torre Jaker about the IRS decision to archive the delinquent FBAR submission procedures. They discuss how the removal eliminates a previously reliable safe harbor, shifting reliance to the harder-to-prove "reasonable cause" defense, and what that means for taxpayers, preparers, and costs. The episode explains the practical differences between the old procedure and reasonable cause, the limits of relying on professional advice, and advice for taxpayers and preparers on handling late FBARs going forward."