I called the E-Filing Regulatory Hotline for FBARs (FinCen) and asked if all “late” FBARs must be filed electronically (e.g., for 2012 and earlier years such as 2011 back through 2007). A rep from the E-Filing Regulatory Hotline called me back and explained that “YES”, the late FBARs must be e-filed; the date of the report should be changed on the e-file to reflect the year for the filing of that particular FBAR. He said that currently the e-filing system does not support the capacity to attach a letter or statement explaining why the FBAR is being filed late. This capacity may become active later this month. They are advising taxpayers to keep all supporting documentation on file because normally the IRS will come back to the taxpayer and ask for it. If you wish to separately send in a paper letter explaining the late filing, then you should reference the confirmation number you get from the e-filing of the late FBAR(s).Thanks, Virginia.
The Regulatory Hotline Number is (800) 949-2732. The Regulatory Hotline only accepts requests at the number provided. They do not provide support via email.
Virginia is a U.S. tax attorney who practices in Dubai. I have found her very knowledgeable about the IRS's offshore iniitiatives. Readers may see her professional summary here.