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FBAR Filing Deadline is About to Change

Aug 4th 2015

Snuck into a short-term highway funding extension bill passed by the Senate on July 30 and signed by President Obama on July 31 was a new filing deadline date for FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR), as well as several other IRS information returns.

Starting for most taxpayers with FBARs filed during 2017, the due date for filing FinCEN Form 114 will change from June 30 to April 15, and taxpayers will be allowed to apply for a six-month extension until Oct. 15. (This is still a couple of months less than taxpayers overseas will have to file their income tax returns, but, hey, it will still be an improvement.)

US persons are required to file with the US Treasury a return commonly known as an FBAR (or Report of Foreign Bank and Financial Accounts – FinCEN Form 114), listing all non-US bank and financial accounts. This is required if on any day of any calendar year a US person (e.g., US citizen, green-card holder, corporation, charity, or trust) has ownership of or signature authority over non-US bank and financial accounts where all accounts have an aggregate (total) balance greater than the equivalent of $10,000.

These forms are separate to – and in addition to – federal income tax returns, and historically, they have always been due by June 30 of each year in relation to the previous calendar year. This date could not be extended. The 2014 FBAR was due to be filed by June 30, 2015, and the 2015 FBAR is due by June 30, 2016. The 2016 FBAR will now be due by April 17, 2017 – but this date can be extended to Oct. 16, 2017.

FBARs (reporting non-US financial accounts with both ownership and signature authority, even if there is no financial interest in the accounts) typically require conversion into US dollars using the US Treasury exchange rate on Dec. 31 of each year. The official FBAR exchange rates can be found on the IRS website.

FBAR forms are currently prepared by downloading a blank form available on the US Treasury website which is prepared, saved, and then re-uploaded and filed when ready.

About the author:
David Treitel writes the “Advising the American Client” blog on AccountingWEB UK. He is director of American Tax Returns Ltd., a leading firm of dually US- and UK-qualified tax advisors who prepare both US and UK tax returns and provide sensible practical “joined-up” American and British tax advice; all for a simple fee agreed before starting.

Related article:

Business Tax Due Date Changes Part of Highway Bill


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