Foreign account reporting has become one of the most heavily enforced areas of U.S. international tax compliance. As global information-sharing initiatives expand and offshore transparency increases, regulators are scrutinizing foreign financial accounts more closely than ever. For practitioners advising cross-border clients, a working mastery of FBAR compliance is no longer optional—it is essential.
The Report of Foreign Bank and Financial Accounts (FBAR), filed under the authority of the Financial Crimes Enforcement Network pursuant to the Bank Secrecy Act, carries significant civil penalties for noncompliance. Even inadvertent errors can trigger costly consequences if not properly addressed.
This session delivers a clear, practical breakdown of the FBAR framework and the standards regulators expect taxpayers and practitioners to meet. Participants will gain clarity on:
Who qualifies as a “U.S. person” for FBAR purposes.
What constitutes a “foreign financial account”
How financial interest and signature authority are defined.
When indirect ownership or control creates reporting obligations.
The program also walks through the mechanics of compliance, including how to determine maximum account values during the reporting year, how to aggregate multiple accounts, and how currency conversion rules apply. Common pitfalls—such as incomplete reporting, misunderstanding joint ownership, or failing to account for dormant accounts—are examined in detail.
A critical portion of the session focuses on enforcement risk. Participants will explore the distinction between willful and non-willful violations, including:
The IRS’s interpretation of willfulness.
Behavioral indicators and red flags.
Recordkeeping considerations.
How facts and circumstances influence penalty exposure.
Through practical examples and real-world scenarios, attendees will learn how to evaluate risk, correct past errors appropriately, and guide clients toward defensible compliance positions.
Specific Topics:
FBAR filing requirements and key regulatory definitions.
Understanding civil penalties and violation standards.
Willful vs. non-willful considerations.
Best practices for accurate and compliant filings.
Learning Objectives:
By the end of this program, participants will be able to:
Identify which taxpayers are required to file an FBAR under current federal law, including individuals, entities, and those with signature authority over foreign accounts.
Determine which foreign financial accounts are reportable, and accurately calculate maximum and aggregate account balances in accordance with regulatory standards.
Distinguish between willful and non-willful FBAR violations, recognizing the behavioral and factual indicators that influence enforcement outcomes.
Implement best practices for accurate, timely, and defensible FBAR submissions, reducing audit exposure and penalty risk.
Credits and Other information:
Recommended CPE credit – 2.0
Recommended field of study – Taxes
Session Prerequisites and preparation: None
Session learning level: Update
Location: Virtual/Online
Delivery method: Group Internet Based
Attendance Requirement: Yes
Session Duration: 120 minutes
Who Will Benefit:
CPA
Enrolled Agents (EAs)
Tax Professionals
Attorneys
Other Tax Preparers
Finance professionals
Financial planners
About Our Speaker
Michael DeBlis,JD,LLM,BA
Michael is a trial lawyer. He graduated Cum Laude from The Thomas M. Cooley Law School and Summa Cum Laude from the Thomas Jefferson School of Law with his Masters of Law in Taxation. Michael is known for his charismatic personality and his unyielding dedication to his clients.
Michael spent the first five years of his legal career as a public defender in the NJ Office of the Public Defender cutting his teeth on some of the most serious felony cases to pass through the state courts of New Jersey. He then joined his father’s law practice, DeBlis Law, expanding the practice into civil tax controversies and international tax compliance.
As a graduate of the National Criminal Defense College, Michael has trained under some of the best-known criminal defense attorneys in the country. That experience has taught him that justice for a person accused of a crime is only won through a full understanding of the client and the case.
