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Hot News! FBAR Filing Dates are Changing... But Not Quite Yet!

3rd Aug 2015
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Snuck into a Short-term highway funding extension act passed by the Senate on Thursday - and signed by President Barack Obama on Friday, 31 July - we will now soon have a new filing deadline date for FinCEN Form 114, Report of Foreign Bank and Financial Accounts (the FBAR form), as well as several other IRS information returns.

Starting - for most taxpayers - from FBARs filed during 2017, the due date for filing FinCEN Form 114 will change from 30 June to 15 April; and taxpayers will be allowed to apply for a six-month extension until 15 October.  (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.)

What is an FBAR?

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. These are 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 are separate to and in addition to United States income tax returns and historically have always been due to be filed by 30 June each year in relation to the previous calendar year. This date could not be extended.  The 2014 FBAR was due to be filed by 30 June 2015 and the 2015 FBAR similarly by 30 June 2016.  The 2016 FBAR will now be due to be filed by 17 April 2017; but this date can be extended to 16 October 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 31 December 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.

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