FBAR Compliance for Italians with US Assets

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.

Who must file the FBAR and what happens if you never did

Who must file the FBAR

What FBAR compliance and back-filing include

What we deliver

Italians in the U.S. and U.S. persons in Italy who must report accounts

Who it's for

Cost of FBAR filing and voluntary regularisation

Pricing

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.

FBAR thresholds, deadlines and penalties — answered

What is the deadline for filing the FBAR?

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.

What is the penalty for not filing the FBAR?

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.

Is the FBAR the same as Quadro RW?

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.

Is FBAR the same as Form 8938?

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.

I haven't filed for years — what do I do?

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.

Do I file FBAR if my US accounts are below $10,000?

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.

Does the FBAR apply to my Florida LLC's bank account?

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.

Can my US CPA file the FBAR for me?

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.

Related services

Where we work — office and areas served

FBAR Compliance for Italians with US Assets is handled from our Florida practice for Italian clients living in the United States and in Italy: office in St. Petersburg (Pinellas County, Tampa Bay), assistance across Florida — including Miami and South Florida — and remotely throughout Italy.

Physical office (by appointment): IIILEX International Consulting LLC, 7901 4th St N STE 300, St. Petersburg, FL 33702, US · +1 (786) 604-8763 · +39 335 344 9660 · us@3lex.us

Areas served

Office hours: Monday to Friday, 09:00–18:00 (US Eastern Time). Italian clients are also served in the Italian morning window (CET). Working languages: Italian and English.

Consultations are held online (video call) or in person at the St. Petersburg office. Documents are exchanged securely by e-mail.


Next step — book a 45-minute online consultation

Book a consultation (USD 250 · 45 minutes) · Send a contact request

About the firm

IIILEX International Consulting LLC is the Florida-based practice of Avv. Dott. Massimo Leonardi — Italian-qualified Attorney (Avvocato), Dottore Commercialista and Statutory Auditor (Revisore Legale), qualified in Italy, with 30+ years of Italian practice. We work exclusively on cross-border matters between Italy and the United States, in coordination with licensed U.S. professionals for matters of U.S. law.

IIILEX International Consulting LLC · 7901 4th St N STE 300, St. Petersburg, FL 33702 · us@3lex.us · +1 (786) 604-8763 · +39 335 344 9660

Versione italiana

Massimo Leonardi is admitted to practice law in Italy and is not admitted to practice law in Florida or elsewhere in the United States. He is qualified in Italy as Dottore Commercialista and Revisore Legale and is not a U.S. Certified Public Accountant. IIILEX International Consulting LLC provides cross-border consulting and Italian legal and tax advisory services. Matters requiring advice on U.S. or Florida law are handled in coordination with appropriately licensed U.S. professionals.