Q. Who must file an FBAR?
A. Any United States person (citizen or resident) who has a financial interest in or signature authority over any financial account in a foreign country, if the aggregate value of such accounts exceeds $10,000 at any time during the calendar year, must file an FBAR.
Q. What is the deadline for filing FinCEN Form 114 (formerly Form TD F 90-22.1), Report of Foreign Bank and Financial Accounts, to report interests in foreign accounts held during the 2014 calendar year (the “2014 FBAR”).
A. June 30, 2015
Q. Can you request an extension of the FBAR due date?
A. No. Extensions of the FBAR filing due date are not available.
Q. If my Income Tax Return extension has been granted, does that extend my FBAR filing due date as well?
A. No. The granting, by the IRS, of an extension to file Federal Income Tax Returns does not extend the due date for filing an FBAR.
Q. What if your foreign accounts were closed during the 2014 calendar year?
A. A 2014 FBAR must be filed even if all foreign accounts required to be reported were closed during the 2014 calendar year.
Q. Do foreign account holders participating in the Offshore Voluntary Disclosure Initiative or Streamline Filing Compliance have to file the FBAR by June 30?
A. Yes, those involved in the Offshore Voluntary Disclosure Initiative or Streamline Filing Compliance must file a 2014 FBAR by June 30, 2015, if they met the $10,000 threshold at any time during the 2014 calendar year.
Q. What if you do not have all the information you need to file your 2014 FBAR by June 30?
A. The IRS advises that, “If a filer does not have all the available information to file the return by June 30, they should file as complete a return as they can and amend the document when the additional or new information becomes available.”
If you have any questions, feel free to contact me directly.
Goldburd McCone LLP