Demystifying the FBAR: Offshore Reporting Rules, Risks & Compliance

Date & Time Wed, December 9, 2026

10:00 AM PST 01:00 PM EST

Duration 90 Mins

Webinar ID IQW26L1245

Level Basic

Speaker Mr.Michael DeBlis III

What you'll learn?

Learn the purpose of the FBAR regulations Determine who must file the FBAR Determine the FBAR filing requirements Determine who is exempt from the FBAR filing requirements Understand the civil and criminal penalties that may be applicable for not complying with the FBAR filing requirements Major Subjects.

Module I: Deconstructing the FBAR rule (Part I)
Module II: Deconstructing the FBAR rule (Part II)
Module III: Most Commonly Asked Questions About the FBAR.
Module IV: IRS Procedures for Ensuring Consistency and Effectiveness in Administering Civil FBAR Penalties.
Module V: The Elusiveness of Willfulness.
Module VI: Beyond the FBAR – Everything You Never Wanted to Know About All of the Other International Reporting Forms but Must.
Module VII: Challenging the IRS’s Assertion of the Non-willful FBAR Penalty: A New Hope.

Overview of the webinar

Beyond FBAR, the deck surveys the broader universe of international reporting forms—Forms 3520, 3520-A, 5471, 5472, 8865, 8938, and others—detailing their purposes and penalties. It closes with an in-depth discussion of how taxpayers can challenge non-willful FBAR penalties, using Moore v. United States as a case study. The Moore litigation illustrates constitutional and administrative challenges, the IRS’s burden to justify penalty amounts, and how courts evaluate whether the agency acted arbitrarily or capriciously. Ultimately, the presentation marries technical instruction with strategic guidance, aiming to help practitioners translate complex statutory and regulatory rules into clear advice for clients while recognizing the increasingly aggressive enforcement environment surrounding offshore compliance.

Who should attend?

Tax Attorneys
Tax Controversy Professionals
CPAs
Accountants
Enrolled Agents
Tax advisors and Consultants
Financial Advisors and Wealth Managers
Bankers and Financial Services Professionals
International Tax and Cross-border Tax Specialists
Compliance and Risk Professionals
Estate and Trust Professionals
Family Office Professionals
Corporate Finance and Legal Teams Managing International Accounts
Professionals Advising U.S. Taxpayers with Foreign Financial Accounts

Why should you attend?

This course provides a comprehensive, practitioner-oriented breakdown of U.S. foreign account reporting rules under the Bank Secrecy Act, focusing especially on FBAR (FinCEN Form 114). It begins by explaining the U.S. system of worldwide taxation and how it triggers foreign reporting requirements, then walks through each element of the FBAR rule: who qualifies as a U.S. person, what counts as a foreign financial account, how financial interests and signature authority are defined, and how to calculate maximum and aggregate balances. The presentation highlights common misunderstandings, explores edge-case scenarios (including online poker accounts), and answers frequently asked questions about filing deadlines, violations, statutes of limitations, and how penalties are determined. It also dedicates significant attention to the distinction between willful and non-willful violations, discussing evidentiary standards, “badges of fraud,” willful blindness, and the pivotal role of Schedule B in establishing constructive knowledge of FBAR obligations.

Faculty - Mr.Michael DeBlis III

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 six 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. When he's not in the courtroom, you can find Michael on stage. He is a professionally-trained actor who has performed in off-Broadway productions and on-stage at Shakespeare in the Park. Michael's passionate about helping trial lawyers harness the power of persuasion and positive communication in the courtroom in order to connect to the jury on a human level.Michael's training as an actor allows him to combine a unique blend of left-brain thinking with right brain artistry to make even the most dull and abstract areas of the law come to life. Michael is a prolific writer and a frequent lecturer at CLE and CPE programs throughout the country. He has written articles that have been featured in leading tax journals and "Law 360." Michael is a living example of the tremendous power that comes from combining passion, preparation, persuasion, and positive communication in the courtroom. His courage and relentless work ethic have earned him a reputation as a zealous advocate and one of New Jersey’s rising stars of the legal profession.

Thank you for your interest in becoming a part of our faculty. GRCForte is continuously looking for excellent individuals from diverse professions to add to our faculty records. Please complete the form below to be considered for our training arrangements in your area of expertise and then submit the form; we will get back as soon as possible.