If you are an Italian resident with US accounts above $10,000 aggregate at any point in the year, you must file the FBAR. The penalties for omission can exceed the account balances.
FBAR (FinCEN 114) preparation, Quadro RW coordination and voluntary disclosure advisory for Italian residents with US accounts.
Fixed fee defined case-by-case after a preliminary consultation, based on the number of accounts, years involved and whether a Streamlined or Voluntary Disclosure path is required. The preliminary consultation is a 45-minute paid online session ($250); the engagement letter with the agreed fee is signed before any chargeable work begins.
The FBAR is due April 15, with an automatic extension to October 15. Unlike the US income tax return, no separate extension request is needed — the October 15 extension is automatic.
Non-willful failure: up to $10,000 per account per year (adjusted for inflation). Willful failure: the greater of $100,000 or 50% of the maximum account balance, per account per year, plus potential criminal exposure including imprisonment up to 5 years for the most egregious cases.
No — they are different filings to different jurisdictions, with different thresholds and different forms. Italians with US accounts above $10K must file both. Critically, the data must match: Italian Agenzia delle Entrate and US FinCEN both receive the data and inconsistencies trigger inquiries.
No. Form 8938 (FATCA) is filed with the IRS as part of Form 1040 and applies to Italians who are US tax residents with foreign accounts above higher thresholds ($50K single / $100K joint, with higher thresholds for residents abroad). FBAR goes to FinCEN and applies at $10K. They overlap but are separate.
Most Italian residents qualify for the Streamlined Foreign Offshore Procedures if the non-filing was non-willful. This typically means: 3 years of amended/delinquent income tax returns, 6 years of FBAR, a non-willfulness certification (Form 14653), and no penalty other than tax + interest on the income returns. We assess eligibility and execute the program.
If the aggregate of all your US accounts (bank, brokerage, financial) at any point during the calendar year never exceeded $10,000 even by one dollar, you do not file. Even one day above $10,000 in aggregate triggers the requirement.
If the LLC's bank account is above $10K and you have signature authority or a financial interest, yes — you file FBAR personally. The LLC itself does not file.
Yes, but most US CPAs do not coordinate the Quadro RW alignment, which is where the Italian risk concentrates. We file the FBAR while ensuring it matches the Italian declarations, which is the value of an Italian-side advisor.
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IIILEX International Consulting LLC is the Florida-based practice of Avv. Dott. Massimo Leonardi — Italian Attorney (Avvocato), Certified Public Accountant (Dottore Commercialista) and Statutory Auditor (Revisore Legale) with 30+ years of Italian practice. We work exclusively on cross-border matters between Italy and the United States.
IIILEX International Consulting LLC · 7901 4th St N STE 300, St. Petersburg, FL 33702 · us@3lex.us · +1 (786) 604-8764 · +39 335 344 9660