Expat becomes FBAR-compliant safely

This is a real example of our work in international & non-resident tax. Below is the client's situation, exactly how our IRS Enrolled Agent approached it, the outcome, and what it means for anyone facing something similar.
The client & the challenge
A US expat had unreported foreign accounts and feared harsh penalties.
Situations like this rarely improve on their own. The right move is to get a licensed representative involved early, before penalties, interest, or enforcement escalate.
Our approach
We used the Streamlined Procedures to file FBARs and amended returns.
How we handle cross-border tax:
- 1Map the obligations. We identify exactly which US filings apply — FBAR, FATCA (8938), 5472, 1040-NR, or ITIN — based on your status.
- 2Get you an ITIN. As a Certifying Acceptance Agent we verify documents in-office and file the W-7, so passports never leave your hands.
- 3Come into compliance. For unfiled years we use the Streamlined Procedures and reasonable-cause relief to avoid or abate penalties.
- 4Apply treaty positions. We claim the correct treaty rates and exclusions (like the Foreign Earned Income Exclusion) so you are not double-taxed.
- 5Set an annual routine. We build a simple recurring filing plan so you stay compliant going forward.
The outcome
Full compliance achieved with penalties avoided.
Understanding International & Non-Resident Tax
US tax rules reach across borders. US citizens and residents are taxed on worldwide income and must report foreign accounts (FBAR/FATCA). Non-residents and foreign-owned US LLCs face their own filings — Form 5472, 1040-NR, and ITIN applications — where mistakes carry severe penalties (a missed Form 5472 alone is $25,000 per year).
As a Certifying Acceptance Agent, we handle ITIN (Form W-7) applications without you mailing original passports, and we bring expats and foreign owners into compliance using the right programs and treaty positions.
International facts worth knowing:
- US citizens abroad must file even with no US income — the FEIE and foreign tax credit usually prevent double tax.
- A missed Form 5472 (foreign-owned US LLC) carries a $25,000-per-year penalty.
- FBAR is required if foreign accounts exceed $10,000 in aggregate at any point in the year.
- The Streamlined Procedures let non-willful filers catch up penalty-free.
Frequently asked questions
Do I have to mail my passport for an ITIN?
No. As a Certifying Acceptance Agent we verify your documents directly, so your passport stays with you.
I'm an expat who never filed — am I in trouble?
Usually not if it was non-willful. The Streamlined Procedures let you catch up without penalties.
My US LLC has a foreign owner — what do I file?
A pro-forma 1120 plus Form 5472 each year. Missing it is a $25,000 penalty, so this is critical.
Will I be taxed twice?
Generally no — treaties, the Foreign Earned Income Exclusion, and foreign tax credits are designed to prevent double taxation.
Key takeaways
- Outcome: Compliant — FBAR filed.
- Handled by a federally licensed IRS Enrolled Agent, start to finish.
- Available remotely to individuals and businesses in all 50 states.
- The sooner you act, the more options you have — waiting adds penalties and interest.
This case study is a representative example based on a real client engagement. Names and identifying details are omitted for privacy. Individual outcomes depend on your specific facts and IRS determinations; results are not guaranteed. See our disclaimer.
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