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Verni Tax Law

FBAR Streamlined Filing Services for U.S. Taxpayers

Get your filings corrected, reduce exposure to IRS scrutiny, and move forward with a process designed for accuracy and acceptance, handled directly by Anthony N. Verni, Attorney at Law (CPA, MBA).

Request a Confidential Case Review Today

What Is FBAR Streamlined Filing?

FBAR Streamlined Filing refers to the IRS’s special compliance program that allows U.S. taxpayers with unreported foreign financial accounts to come into compliance without facing full penalties as long as the failure to file was non-willful.

This program is formally known as the Streamlined Filing Compliance Procedures (SFCP) and is available in two forms:

  • Streamlined Foreign Offshore Procedures (for qualifying U.S. taxpayers living abroad), and
  • Streamlined Domestic Offshore Procedures (for qualifying U.S. taxpayers living in the United States).

It is designed to help individuals and businesses correct past filing mistakes related to FBAR (FinCEN Form 114) and foreign income without triggering harsh enforcement actions or audits.

Who Qualifies for Streamlined FBAR Filing?

To use the streamlined procedures, the taxpayer must meet all of the following criteria:

  • Non-willful conduct: The failure to report foreign accounts or income must not have been intentional.
  • Valid Tax Identification: You must have a Social Security Number (SSN) or Individual Taxpayer Identification Number (ITIN).
  • No active IRS investigation or audit: You are not eligible if the IRS has already initiated contact regarding your foreign accounts.
  • Residency requirement (for foreign procedures only): You must meet the IRS’s test for living outside the U.S.

Verni Tax Law conducts a full eligibility assessment before beginning any filing under this program. This ensures your submission aligns with IRS expectations and avoids unnecessary risk.

Not Sure If You Qualify? Let’s Review Your Options Privately

If you're unsure whether the Streamlined Filing route fits your situation, Anthony N. Verni will review your case with complete confidentiality before any steps are taken.

A single consultation could help you resolve years of uncertainty.
Request a Confidential Case Review

Key Benefits of Streamlined Filing

The FBAR Streamlined Filing Compliance Procedures offer significant legal and financial advantages for eligible taxpayers. When handled correctly, this program helps resolve past reporting issues while minimizing exposure to future IRS actions.

The main benefits include →

  • Limited Penalty Exposure: Eligible taxpayers can avoid the 50% willful FBAR penalty and instead face either no penalty (for foreign residents) or a capped 5% penalty (for U.S. residents), significantly reducing financial risk.
  • Resolution Without Formal IRS Investigation: Streamlined filings are reviewed through a compliance-based process, not a full audit, which means qualifying taxpayers can correct their records without triggering a detailed IRS examination.
  • Clear Path to Compliance: The program outlines exactly what to submit, which is three years of amended tax returns, six years of FBARs, and the non-willfulness certification, creating a defined, manageable process with predictable outcomes.
  • Reinstatement of Filing Rights and Refund Claims: Taxpayers may become eligible to claim legitimate foreign tax credits, deductions, or refunds that were previously missed due to non-compliance.
  • Closure on Outstanding Offshore Issues: Once accepted, the streamlined submission closes the matter related to past unreported foreign accounts, giving taxpayers peace of mind and preventing future enforcement on those years.

The benefits are real, but only when the filing is done right.

Let’s help you take full advantage of what streamlined compliance offers: no missteps, no missed opportunities, just accurate filings reviewed by an experienced Attorney–CPA who’s handled hundreds of these cases already.
Let’s talk—before this gets harder to undo.

Tax Litigation Process Explained

We follow a precise, step-by-step process to ensure your submission meets all legal and technical requirements under the IRS Streamlined Filing Compliance Procedures.
Step 1

Initial Consultation & Eligibility Assessment

We begin with a confidential consultation to review your tax history, foreign income, and account activity. This helps us determine if you meet the IRS’s non-willful criteria and are eligible for streamlined relief. You’ll receive a clear overview of your options before moving forward.
Step 2

Document Collection & Case Review

Next, we share a personalized checklist of required documents, typically including foreign bank statements, prior tax returns, and income records. Each item is reviewed carefully to ensure your case is fully supported and ready for submission.
Step 3

Return Preparation & FBAR Filing

We prepare three years of amended tax returns, six years of FBARs, and your non-willfulness certification. All filings are completed with full legal accuracy and reviewed line by line to avoid any errors or inconsistencies.
Step 4

Final Review & Submission

Anthony N. Verni, licensed Attorney and CPA, personally reviews your complete file. Once verified, we submit your documents to the IRS using the proper method, whether electronically or by mail.
Step 5

IRS Follow-Up & Representation

After submission, we track the status of your case and remain available to address any IRS follow-up. If the IRS contacts you, we respond directly on your behalf, helping you stay compliant with no further delays or confusion.
Step 1

Initial Consultation & Eligibility Assessment

We begin with a confidential consultation to review your tax history, foreign income, and account activity. This helps us determine if you meet the IRS’s non-willful criteria and are eligible for streamlined relief. You’ll receive a clear overview of your options before moving forward.
Step 2

Document Collection & Case Review

Next, we share a personalized checklist of required documents, typically including foreign bank statements, prior tax returns, and income records. Each item is reviewed carefully to ensure your case is fully supported and ready for submission.
Step 3

Return Preparation & FBAR Filing

We prepare three years of amended tax returns, six years of FBARs, and your non-willfulness certification. All filings are completed with full legal accuracy and reviewed line by line to avoid any errors or inconsistencies.
Step 4

Final Review & Submission

Anthony N. Verni, licensed Attorney and CPA, personally reviews your complete file. Once verified, we submit your documents to the IRS using the proper method, whether electronically or by mail.
Step 5

IRS Follow-Up & Representation

After submission, we track the status of your case and remain available to address any IRS follow-up. If the IRS contacts you, we respond directly on your behalf, helping you stay compliant with no further delays or confusion.

Tax Litigation Process Explained

We follow a precise, step-by-step process to ensure your submission meets all legal and technical requirements under the IRS Streamlined Filing Compliance Procedures.
Step 1

Initial Consultation & Eligibility Assessment

We begin with a confidential consultation to review your tax history, foreign income, and account activity. This helps us determine if you meet the IRS’s non-willful criteria and are eligible for streamlined relief. You’ll receive a clear overview of your options before moving forward.
Step 2

Document Collection & Case Review

Next, we share a personalized checklist of required documents, typically including foreign bank statements, prior tax returns, and income records. Each item is reviewed carefully to ensure your case is fully supported and ready for submission.
Step 3
We prepare three years of amended tax returns, six years of FBARs, and your non-willfulness certification. All filings are completed with full legal accuracy and reviewed line by line to avoid any errors or inconsistencies.
Step 4

Final Review & Submission

Anthony N. Verni, licensed Attorney and CPA, personally reviews your complete file. Once verified, we submit your documents to the IRS using the proper method, whether electronically or by mail.
Step 5

IRS Follow-Up & Representation

After submission, we track the status of your case and remain available to address any IRS follow-up. If the IRS contacts you, we respond directly on your behalf, helping you stay compliant with no further delays or confusion.

Confidence Doesn’t Come From Filing; It Comes From Doing It Right

When every step is handled with care, reviewed by an experienced Attorney–CPA, and submitted with precision, you get more than compliance; you get peace of mind.

Let’s make sure your filing closes the door on past issues, for good.
Book Your Review Today →

Why Choose Verni Tax Law for Streamlined FBAR Filing

Successful Track Record in IRS and FBAR Compliance

We have consistently resolved complex offshore disclosure cases under the Streamlined Filing Compliance Procedures. Our focus is on accuracy, timeliness, and meeting every IRS requirement.

25+ Years Handling U.S. Tax and Legal Matters

With over two decades of experience addressing U.S. tax law and procedure, we understand how to approach foreign income and reporting issues with clarity and precision.

Dual Credentials: Attorney–CPA–MBA

Your matter is personally handled by Anthony N. Verni, Attorney at Law (CPA, MBA). This combination of legal, tax, and financial expertise provides a comprehensive, professional approach to every case.

Support for U.S. Taxpayers Living in the U.S. or Abroad

We assist individuals and businesses, whether residing in the United States or overseas, who have U.S. tax obligations linked to foreign accounts, income, or assets.

Flat Fees with No Hidden Charges

Every engagement is quoted transparently at the beginning. You’ll know exactly what to expect, with no hourly rates or surprise fees added along the way.

Private, One-on-One Representation

All matters are handled directly and confidentially. You are never passed between departments, and your information is treated with the highest level of professional care.

About Verni Tax Law

Verni Tax Law is a boutique law practice focused exclusively on serious IRS and tax controversy matters. Founded by Anthony N. Verni, a licensed tax attorney, CPA, and MBA with over 20 years of experience, the firm delivers legal and financial representation rooted in clarity, precision, and integrity.

Anthony represents U.S. taxpayers across all 50 states and globally wherever U.S. tax obligations apply. Every case is approached with discretion, strategic insight, and a commitment to achieving fair, defensible outcomes.

Frequently Asked Questions

There is no fixed deadline, but the program is available only as long as the IRS keeps it open. Once the IRS ends the Streamlined Filing Compliance Procedures, taxpayers can no longer use them. Filing sooner helps reduce risks if the IRS initiates contact or ends the program.

No. If the IRS has already contacted you about your foreign accounts or tax filings, you are not eligible for streamlined filing. Eligibility requires that you are not under civil examination or criminal investigation when you submit.

You must file:

  • Three years of amended tax returns (Forms 1040X)
  • Six years of FBARs (FinCEN Form 114)
  • A signed certification of non-willfulness (Form 14654 or 14653, depending on your residency)

There is no official timeframe, but most submissions are processed within 6 to 12 months. Delays may occur if the IRS requests additional documentation or if the submission is incomplete.

Mistakes can lead to rejection of the submission or further IRS inquiry. If the IRS believes you were willful, they may impose higher penalties or pursue other enforcement actions. Accuracy and legal clarity are essential.

Yes. FBARs (FinCEN Form 114) are submitted electronically through the BSA E-Filing System, even when filed as part of a streamlined submission.

If you don’t qualify, you may face willful FBAR penalties, which can be as high as 50% of the account balance per year. In serious cases, criminal penalties may also apply. Other options like the IRS Criminal Investigation Voluntary Disclosure Practice may be necessary.

You must submit a signed statement explaining your lack of intent to violate U.S. tax laws. This includes detailing how the mistake occurred and why you didn’t know your reporting obligations. Supporting records, email correspondence, or testimony may strengthen your case.

Yes. The streamlined process is designed to correct past noncompliance over a defined period, which is three years of amended returns and six years of FBARs. All required years must be submitted at once.

While not mandatory, professional guidance is strongly recommended. The process requires legal and tax accuracy, and any errors could lead to penalties or rejection. Working with an experienced Attorney–CPA helps ensure your submission is correct and defensible.

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Hear from relieved
Taxpayers who trusted Verni Tax Law

Anthony was creative in helping me resolve some past issues in a way that they never became a problem so that is greatly appreciated and I feel confident I can now enjoy my retirement with peace of mind. Thanks for that.

Ken B.

Cebu City, Philippines

Anthony was creative in helping me resolve some past issues in a way that they never became a problem so that is greatly appreciated and I feel confident I can now enjoy my retirement with peace of mind. Thanks for that.

Douglas R.

Osaka, Japan

Anthony was creative in helping me resolve some past issues in a way that they never became a problem so that is greatly appreciated and I feel confident I can now enjoy my retirement with peace of mind. Thanks for that.

Phil Y

President, Swift & Secure Systems Inc., Boynton Beach, FL

Anthony was creative in helping me resolve some past issues in a way that they never became a problem so that is greatly appreciated and I feel confident I can now enjoy my retirement with peace of mind. Thanks for that.

Yassin and Eva, B.

President, Swift & Secure Systems Inc., Boynton Beach, FL

Have questions or need guidance?

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