Additional FBAR Procedural and Reporting Information Questions

Additional FBAR Procedural and Reporting Information Questions

Additional FBAR Procedural and Reporting Requirements

When it comes to reporting the annual FBAR, there are many moving parts for US Persons to consider in facilitating overall tax and reporting compliance with international disclosures. While the main form is FinCEN Form 114 – in which the taxpayer provides the maximum account value of their foreign bank and financial accounts, — there are other reporting requirements ancillary to the FBAR, which are still impacted by FBAR filing. For example, a taxpayer may also have to file an IRS Schedule B in order to identify their foreign accounts – in which the form also requires the Taxpayer to confirm whether or not the taxpayer also filed an FBAR. Let’s take a brief look at what the IRS provides for matters involving procedural and reporting information in order to fulfill the FBAR reporting requirement.

As provided by the IRS:

Procedural and Reporting Information Fulfilling the Reporting Requirement

Filers report their foreign accounts by:

• • • (1) completing and timely filing the FBAR electronically; and

    • (2) answering FBAR-related questions on federal tax and information returns such as:

      • • Form 1040, Schedule B, questions 7a and 7b;

        • Form 1041, “Other Information” section, question 3;

        • Form 1065, Schedule B, question 8; or

        • Form 1120, Schedule N, questions 6a and 6b.

Due Date of FBAR

• • • The FBAR is a calendar year report and must be received by the Department of the Treasury on or before April 15th of the year following the calendar year being reported. Before the Surface Transportation and Veterans Health Care Choice Improvement Act of 2015, the filing dead – line for calendar year 2015 and earlier reports was June 30th, with no provision for requesting an extension of time to file an FBAR. For FBARs due for calendar year 2016 and subsequent years, the Act mandated the FBAR filing due date change to April 15th and provided for a maximum six-month extension of the filing deadline.

    • To implement the statute with minimal burden to the public, FinCEN will grant filers failing to meet the FBAR annual due date of April 15th an automatic extension to October 15th each year. Filers don’t need to specifically request this extension.

    • If a filer doesn’t have all information available to file the FBAR by the auto matic extension date of October 15th, the filer should file as complete an FBAR as possible and amend it when more or new information becomes available. Refer to the electronic filing instructions for information on filing amended FBARs.

Where to File an FBAR

• • • Don’t file the FBAR with the Federal tax return.

      • Electronic filing of FBARs became mandatory July 1, 2013. File FBARs through the BSA E-Filing System. Electronic filing is a quick and secure way for individuals to file FBARs. Filers will receive an acknowledgment of each submission. 

    • Resources for FBAR Filers:

      • Get help with completing the FBAR Monday through Friday, 8 a.m. to 4:30 p.m. Eastern Time at 866-270-0733 (toll-free inside the United States) or 313-234-6146 (not toll-free, for callers outside the United States).

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