Webinar: Coming out of the Dark - Episode 3: FBAR and Form 8938 Penalties by ALFI

ALFI

Join Matt Eddleman for practical guidance on advising clients through foreign account disclosure and penalty mitigation.

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Presenter

Matt Eddleman

Matt Eddleman brings more than two decades of professional experience in tax controversy, accounting, financial planning, and small business management to Frost Law's Tax Compliance team.

About

Continuing his compliance series, Matt Eddleman covers foreign account reporting obligations and the penalty risks that follow when they go wrong.

Agenda

Identify the filing thresholds, deadlines, and statutory basis for FinCEN Form 114 (FBAR) and IRS Form 8938.
Calculate civil penalty exposure for non-willful and willful FBAR violations under current inflation-adjusted maximums and the per-report standard of Bittner v. United States.
Distinguish non-willful conduct from willful or reckless disregard, and assess the sufficiency of a reasonable-cause or non-willfulness certification.
Evaluate remediation options — SFOP, SDOP, DFSP, DIIRSP, and the Voluntary Disclosure Practice — and select the program appropriate to a client's facts.
Apply recent regulatory developments, including the 2026 removal of the DFSP webpage and the Schwarzbaum Eighth Amendment holding, to current client advisement.