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FBAR filing deadline reminder: the old and the new

Across the country, the school year is winding down. Many graduations have already been held, with some still to come.

But for taxpayers with foreign accounts valued at more than $10,000, summer comes with an important filing requirement.

In this post, we will provide a reminder of the June 30 deadline for filing the FBAR form. FBAR stands of course for Report of Foreign Bank and Financial Accounts.

The $10,000 figure is a pretty basic round number. But it can be a complicated question as to who must file an FBAR.

For example, there may be an issue regarding whether someone with "signatory authority" over an account has to file. As we discussed in our April 22 post last year, the money managers and others involved with offshore accounts may have certain reporting requirements.

The IRS and the Financial Crimes Enforcement Network (FinCEN) have been seeking to clarify these requirements under the Bank Secrecy Act and other federal laws.

It is also important to recognize that the FBAR form and new reporting requirements regarding the Foreign Account Tax Compliance Act (FATCA) are not necessarily in alignment. We discussed that issue in our June 7 post last year.

Keep in mind, as you consider this year's filing requirement, that there is a new form involved.

The old form was called TD F 90-22.1.The new one is called FinCEN Form 114.

In short, the June 30 filing deadline for FBAR forms may be a yearly ritual. But there is always something new too.

Source:, "Report of Foreign Bank and Financial Accounts (FBAR," Accessed June 4, 2014

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