The IRS generally has six years after “the transaction with respect to which the penalty is assessed” to impose a civil penalty related to an FBAR violation. For penalty purposes the assessment date is when the IRS stamps the Form 13448, Penalty Assessments Certification Summary. While the civil statutes on assessment and collection of the FBAR penalty can be waived, a waiver of limitations for purposes of a Title 26 audit will not extend the limitations with respect to the FBAR penalties. Failure to file a complete and accurate international information return will extend the period of limitations on assessment and collection of any tax imposed with respect to any event or period to which the international information return applies to three years after the date on which the required information is reported.
