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All FBAR's must now be electronically filed. Paper filings are no longer accepted.
The due date for 2016 year FBARs is April 18, 2017 (no longer June 30), however the US government is allowing an automatic extension to October 15, 2017, with no need to file any extension request. The government announcement can be found here.
Clients are responsible for determining their own FBAR filing requirements. If you want Edelman Tax LLC to prepare your FBAR, please let us know well in advance of the deadline. This service is subject to a separate fee and you will need to send us a signed Form 114a authorization.
Do I need to file an FBAR?
Each individual taxpayer must make a separate determination whether he or she needs to file an FBAR. In limited circumstances, one spouse can file jointly for both spouses. More information on joint filings is provided below.
Tip: You may find it helpful to use our FBAR Data Organizer (.xls) to perform the following analysis.
1. Make a list of all the foreign (i.e. non-US) financial accounts that were open at any time during the relevant calendar year that are:
• Your own separate personal account
• An account that you own jointly with someone else
• An account owned by a business entity that you own more than 50% of
• An account over which you have a signature or other control/authority, but in which you have no financial interest (e.g., the account of an employer or friend/relative, etc).
"Foreign financial account" includes any non-US based:
• Bank accounts
• Securities and other investment accounts
• Personal pension/retirement account (but not employer-administered plans or government-administered social security and similar plans)
• Insurance policies with cash surrender value
• Any other financial instrument accounts
Include accounts that were open at any time during the relevant year, even those that had minimal or even zero balances. Accounts located in the United States are not relevant.
2. For each account in your list, determine the single highest balance reached by that account (in whichever currency) during the calendar year. Then, convert non-USD to USD using the rates posted at this IRS website.
3. After determining the maximum annual balance for each foreign account and converting all these amounts to USD, add up all of these maximum figures. If the resulting sum exceeds US$10,000, you are required to file an FBAR. On that FBAR, you must report all of your foreign accounts that were open at any time during the year, even those with minimal or zero balances.
Joint filings with spouse
A joint FBAR filing is allowed only for spouses, and only in circumstances as described in this example:
John has several foreign accounts, including two joint accounts with his wife Mary (who herself has no other foreign accounts). Based on the balances in those accounts, both John and Mary would normally have to file separate FBAR's. However, since Mary's only foreign accounts are those two joint accounts with John, John can file a single FBAR for both of them. In order to do this, Mary must authorize John to file on her behalf by providing John with a signed Form 114a. If Mary has any other account to report besides the joint accounts with John, she would have to file her own separate FBAR.
Resources & filing instructions
FBAR Form (.pdf)
FBAR Form Instructions (.pdf)
Edelman Tax LLC's FBAR Data Organizer (.xls)
Official FBAR Exchange Rates (external site)
1. Make sure you have installed Adobe Reader 9.5 or higher (Adobe X or XI). Note: if you attempt to use an unsupported version of Adobe Reader or Acrobat to prepare the form, your filing will probably be unsuccessful.
2. Note that the online FBAR system no longer requires registration or a login.
3. Download the FBAR form. We suggest renaming the file as follows: yourlastname_YYYY_FBAR. For example, Mr. Smith's 2016 FBAR filename could be Smith_2016_FBAR.
4. Open the form in the supported version of Adobe Reader, fill it out, and re-save the form (overwriting the existing file) using the Save button on the first page.
5. Once the form is complete, sign it by pressing the Sign the Form button on the first page, and then save it once again. At this point you can file the form by pressing the Ready to File button, which will take you to the filing website. Follow the instructions there to complete your FBAR filing.
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