U.S. FBAR Filing Date Now 15 April XX; No Longer 15 Jun XX

[Pib]

For folks required to file a FBAR, the filing date is now 15 April of each year versus 15 Jun barring weekends/holidays causing a slight adjustment in the date.   

 

Basically it's now lined-up with the federal tax refund filing date for each year which is 15 Apr or maybe a few days after depending on what day 15 Apr falls on.  Like this year it's actually 18 Apr since 15-16 Apr is a weekend and 17 Apr is Washington D.C. Emancipation Day.  

 

However, due to the way the law was recently amended the U.S. Treasury grants an "automatic extension" to 15 Oct for FBAR submission.  Request for extension is not required.  

 

See U.S. Treasury FinCen info below.   Also note there is no change in this year's FBAR form (still using formm Ver, 1.0, dated 1 Oct 13)....a person can just pull up last year's submission, update info, and resubmit.  Not hard.

 

https://www.fincen.gov/news/news-releases/new-due-date-fbars-0

Quote

The new annual due date for filing Reports of Foreign Bank and Financial Accounts (FBAR) for foreign financial accounts is April 15. This date change was mandated by the Surface Transportation and Veterans Health Care Choice Improvement Act of 2015, Public Law 114-41 (the Act). Specifically, section 2006(b)(11) of the Act changes the FBAR due date to April 15 to coincide with the Federal income tax filing season. The Act also mandates a maximum sixmonth extension of the filing deadline. To implement the statute with minimal burden to the public and FinCEN, FinCEN will grant filers failing to meet the FBAR annual due date of April 15 an automatic extension to October 15 each year. Accordingly, specific requests for this extension are not required. (Please note: The due date for FBAR filings for foreign financial accounts maintained during calendar year 2016 is April 18, 2017, consistent with the Federal income tax due date.)

 

A few other key FBAR wepages.

https://www.fincen.gov/report-foreign-bank-and-financial-accounts

 

http://bsaefiling.fincen.treas.gov/NoRegFBARFiler.html

 

[JimGant]

And the official fx rate for this year's FBAR is 35.77 https://www.fiscal.treasury.gov/fsreports/rpt/treasRptRateExch/treasRptRateExch_home.htm. Not that any fx rate used could not, would not, be ok if in the ballpark. In fact, that the FBAR threshold remains $10, 000, while the FATCA threshold down the a hallway at IRS is $50,000, is nonsensical, since any FBAR reported figure of less than $50,000 won't make for a "match" against any FATCA figure, which would show income earned. Why, then, all these sub-$50,000 FBAR number submissions that drive nothing?. Who could possibly care about such piddly reporting...? Anyway, maybe the new Treasury Secretary (Munchkin, is it?) will rationalize FBAR and FATCA thresholds.

Edited January 22, 2017 by JimGant
typo

[Pib]

4 minutes ago, JimGant said:

And the official fx rate for this year's FBAR is 35.77 https://www.fiscal.treasury.gov/fsreports/rpt/treasRptRateExch/treasRptRateExch_home.htm. Not that any fx rate used could not, would not, be ok if in the ballpark. In fact, that the FBAR threshold remains $10, 000, while the FATCA threshold down the a hallway at IRS is $50,000, is nonsensical, since any FBAR reported figure of less than $50,000 won't make for a "match" against any FATCA figure, which would show income earned. Why, then, all these sub-$50,000 FBAR number submissions that drive nothing?. Who could possibly care about such piddly reporting...? Anyway, maybe the new Treasury Secretary (Munchkin, is it?) will rationalize FBAR and FATCA thresholds.

 

IRS bean counters care?

 

Maybe Munchkin standardize the amounts to around $100 million as he too apparently has a problem in reporting foreign assets.

http://www.reuters.com/article/us-usa-congress-mnuchin-idUSKBN1530KI

Quote

In a confirmation hearing before the Senate Finance Committee, President-elect Donald Trump's pick to lead the Treasury was attacked for failing to promptly disclose he was a director of an offshore business vehicle domiciled in the Cayman Islands and owned more than $100 million in real estate.

 

 

[Pib]

Hey, I got all motivated and decided to review our (the wife and I) 5 Thai bank accounts data to determine interest earned, highest amounts during the year, etc., for the purposes of FBAR and Federal Return submission.     I download quarterly statements from my Thai bank accounts during the year to keep track of interest earned, highest amount during the year, etc.  I even have some home-made, short & sweet Word worksheets I use to aggregate my bank account data.  With my review and worksheets completed, I just need to pull-up last year's FBAR submission, make a few updates, and click submit again.   Will be done for another year with the FBAR thingie.

 

Now for my Federal Return I'll get serious about that around mid February after I get all my various income docs from my banks, mutual funds, etc. Some of those I will not get until early February like my mutual fund tax docs.  But hey, I can at least say I now have my interested earned info for my Thai bank accounts to enter on the tax return.   Uncle Sam would be proud of me.

 

Since this data review took about 45 minutes to do....I'm thirsty....Leo time.

 

 

 

[tutsiwarrior]

good thread...thanks fer the heads up

[Pib]

And just to correct myself the "old" no later than filing date was 30 Jun vs 15 Jun.

[tutsiwarrior]

I'm confused...in the past I filed an online FBAR  declaration when I thought that more than USD10000 in overseas bank accounts required me to do so...now this year I'm told that I must file a form 8938 with my tax return if my total overseas assets are more than USD200000...

 

 

maybe I'm confusing FATCA with FBAR (the bastids have got ye comin' and goin' when it's none of their <deleted> business to begin with)...is there still a FATCA reporting requirement for 2016?...before it was required that you send the details to a US Treasury Dept address and not to the IRS...I got less than USD200000 in foreign bank accounts and more than USD10000...what should I do?

 

thanks in advance...

[Pib]

16 hours ago, tutsiwarrior said:

I'm confused...in the past I filed an online FBAR  declaration when I thought that more than USD10000 in overseas bank accounts required me to do so...now this year I'm told that I must file a form 8938 with my tax return if my total overseas assets are more than USD200000...

 

 

maybe I'm confusing FATCA with FBAR (the bastids have got ye comin' and goin' when it's none of their <deleted> business to begin with)...is there still a FATCA reporting requirement for 2016?...before it was required that you send the details to a US Treasury Dept address and not to the IRS...I got less than USD200000 in foreign bank accounts and more than USD10000...what should I do?

 

thanks in advance...

You are confusing federal income tax Form 8938 reporting requirements with FBAR (FinCen) reporting requirements....two different animals and different reporting amounts.  See below IRS webpage for a Comparison of of Form 8938 and FinCen reporting requirements/amounts/etc.

 

https://www.irs.gov/businesses/comparison-of-form-8938-and-fbar-requirements

 

 

Regarding the FBAR/FinCen reporting requirements, yes, you must file a report if you had more than $10K aggregate in a foreign account(s) at any time during the year.  

 

 

 

[tutsiwarrior]

thanks, Pib...

 

 

Edited February 27, 2017 by tutsiwarrior

[JimGant]

Quote

.I got less than USD200000 in foreign bank accounts

If you're not living in the US, no Form 8938 need be filed. Even if your real property assets brought you over the 200k hurdle (400k, if married), still no Form 8938, 'cause your house and rental houses aren't counted towards the 200/400k. Thus, few of us reading this probably have to file a Form 8938.

[Pib]

Electronically filed my FBAR on Monday/yesterday...got confirmation of receipt during that filing followed by an email a few seconds later.   And today I got an email which was acknowledgement of filing along with a BSA control number.  

 

Think of it as the "receipt" was just proof you filed/uploaded your FBAR report before any Treasury official had looked at it....and the acknowledgement was review and assignment of a control number for future reference if required.  Summary: done for another year.  

 

Webpage to download/prepare FBAR and to submit FBAR.   And when I say submit, I mean you just upload a completed FBAR you may have accomplished online and then clicked the Ready to Submit buttion on the FBAR PDF form which automatically takes you to the webpage to upload/submit the report.    Whether a person agrees or not with the reasons behind a FBAR report, it's definitely not hard to submit a FBAR.

http://bsaefiling.fincen.treas.gov/NoRegFBARFiler.html

[longball53098]

Your post got me going and just did my FBAR online. They have made it pretty simple. Hardest part is double checking your own numbers and info. About 1 hour for me

[Pib]

Yea, I download the form to my computer each year.   If the form version/date has not changed (and it hasn't for several years...still version 1.0) then I pull up last year's Signed form, click the Remove Signature button which allows me to modify/update the data, update/tweak the data from last year which is normally just updating the dollar amounts and maybe adding or removing a bank account.  Then click the Sign button, then click the Ready to File button which takes me right to the webpage where you enter  you email address and attach the FBAR for upload....click a button and your are done....Uncle Sam has your FBAR at nearly the speed of light.

 

Completion and submission of the form is simple and easy "as long as you know bank account data to put on the form."  

 

What I do is once a quarter I use my ibanking for each bank account, save a quarterly report so I can see my Highest Amount during that quarter....I do this four times a year and then just look at those four statement at the end of the year to see what my highest amount was during the year and that's the figure that goes on the FBAR report converted to dollars. I do it once  quarter since my ibanking only shows data 6 months back and sometimes I forget to do it and might miss a month of data....but doing it once a quarter gives me plenty room for error.    Or if I wanted to I wouldn't have to do any of the Highest Amount tracking and instead just check the "Highest Amount Unknown" block,   but I would rather not imply to Uncle Sam I ain't got a clue what the Highest Amount was during the year.

 

And for other listening in, you do not report interest earned on the FBAR...you only report the Highest Amount During the Year" for each bank account.  Reporting interest earned is done on your tax return.   Your tax return and FBAR are too completely different animals for different but kinda similar purposes....that is to ensure you are reporting financial data possibly subject to tax.  

 

Yeap, nobody could use the excuse of, "The form is too hard to complete and submit"....the judge would probably laugh at you.

 

My FBAR is done....my tax return refund arrives via Direct Deposit today according to the IRS Refund Status page....I filed my tax return on 12 March....about 10 calendar days to get the refund...not bad....one year I got it in 6 days I think.  I'm done with Uncle Sam for another year.   Now I can concentrate watching the daily escapades of Elmer Fudd (a.k.a., Donald Trump).

[Rhys]

hmmm....have not done this ever

 

[Pib]

8 minutes ago, Rhys said:

hmmm....have not done this ever

 

And you don't need to "unless you had over $10K equivalent at any time during the year in a foreign account." 

[Jingthing]

Hi all.

Just did my FBAR.

What fun.

I wasn't in the mood (what is the right mood for filing FBAR?) so it was a little more painful than it should have been.

I had to update Reader and there were technical issues making it the default application for PDF (as it wasn't).

I went with the fill out the PDF offline and upload.

You can also do the entire thing online if you're ready to file with all info, which I think I did last year.

The latter is probably easier but I'm a little more comfortable with doing it offline and being able to save the work before submitting if needed.

 

I can see the "deadline" this year is April 18 and that there is information here expressing confidence that there will be an automatic EXTENSION until June 15.

 

I'm willing to accept that as correct information, but I felt more comfortable filing it by the first deadline (April 18) and to not worry at all about the extension information.

 

Filers, be advised that at least on paper the PENALTIES for not filing if you required to file are incredibly severe. 

 

I don't fool around with FBAR. 

 

[Pib]

4 minutes ago, Jingthing said:

I can see the "deadline" this year is April 18 and that there is information here expressing confidence that there will be an automatic EXTENSION until June 15.

 

The way the  law was revised (thanks Congress) regarding the No Later Than date and extension date it turned out to be confusing/conflicting and would have probably created more work for the U.S. Treasury to process extension requests.  So, until the law wording is possibly fixed by Congress the U.S. Treasury has just set 15 Oct of each year as the NLT date.  See below quote from a Dept of the Treasury website...I underlined the "confusing/conflicting" part and bolded how Treasury has fixed the issued.

 

While the normal FBAR submission date was "meant" to be the same as for your federal tax return in mid April, the messed up wording saying the NLT date is mid Apr but at the same time mandating a 6 month extension drove the U.S. Treasury just to set a NLT date of 15 Oct.   Expect Treasury didn't want to get into a process of having to review/approve/disapprove extension requests so they are automatically giving a 6 month extension to 15 Oct each year....don't even have to ask....it's just automatically exists.  

 

So when the dust settled the old FBAR NLT of 30 June has been stretched out 3.5 months to 15 Oct.   Although the original intent was to put the FBAR due date in sync with your federal return NLT date of mid April, the confusing/conflicting wording ended up stretching out the FBAR date.  Our Congress and Administration/Treasury at work...guess they ought to proof read what they write before being passed into law.

 

But for me, I plan to submit my FBAR within a few days of my federal tax return since I need to collect much of the FBAR data just to complete my tax return when I list my Thai bank accounts and interest earned on my tax return.  I created myself a personal worksheet I use to write down both FBAR and tax return related info.  Then for the FBAR each year I first check to ensure this year's FBAR form has not changed (it has change for several years now)...if the same I just pull up last year's submitted form, click the Unsign button, update the data, digitally Resign the form, and then click the Ready to File button that take your right to the Treasury upload/submission site...not hard.  Most of the time needed for a FBAR is having the financial account info to put on the form such as account number, bank address, Highest Amount during the year, etc.   Since Thai bank's don't send out 1099 interest earned forms or tell you what the highest amount was in the account for the year, that is just something you need to develop a monitoring process for.  For me I just download periodic statements/retrievals every 3 to 6 months from my ibanking and then review those come FBAR/tax return time.

 

https://www.fincen.gov/news/news-releases/new-due-date-fbars-0

Quote

New Due Date for FBARs The new annual due date for filing Reports of Foreign Bank and Financial Accounts (FBAR) for foreign financial accounts is April 15. This date change was mandated by the Surface Transportation and Veterans Health Care Choice Improvement Act of 2015, Public Law 114-41 (the Act). Specifically, section 2006(b)(11) of the Act changes the FBAR due date to April 15 to coincide with the Federal income tax filing season. The Act also mandates a maximum six month extension of the filing deadline. To implement the statute with minimal burden to the public and FinCEN, FinCEN will grant filers failing to meet the FBAR annual due date of April 15 an automatic extension to October 15 each year. Accordingly, specific requests for this extension are not required. (Please note: The due date for FBAR filings for foreign financial accounts maintained during calendar year 2016 is April 18, 2017, consistent with the Federal income tax due date.)

 

 

For those who still have not started/submitted a FBAR if required, below is the Treasury website to either download the form to do it offline or do it online if desired.  Completing the form offline should be easier IMO.   When completed offline then click the Ready to File button on the form and it takes you right to the Treasury webpage where you upload/submit the completed FBAR.   You'll probably need to use  the free Adobe Reader to open/complete the form as some pdf readers such as the built-in Chrome pdf reader may not work with the form.

 

http://bsaefiling.fincen.treas.gov/NoRegFBARFiler.html

 

 

[Jingthing]

Yes to all that but happy I did it already.

[Jingthing]

Now that we're on extensions my understanding is that federal IRS deadlines are automatically extended for those abroad without need for filing an extension request. That automatic extension is what date?

[Pib]

8 minutes ago, Jingthing said:

Now that we're on extensions my understanding is that federal IRS deadlines are automatically extended for those abroad without need for filing an extension request. That automatic extension is what date?

 

https://www.irs.gov/individuals/international-taxpayers/taxpayers-living-abroad

 

Quote

 

When to File

If you are a U.S. citizen or resident alien residing overseas, or are in the military on duty outside the U.S., on the regular due date of your return, you are allowed an automatic 2-month extension to file your return without requesting an extension. For a calendar year return, the automatic 2-month extension is to June 15.  Note that you must pay any tax due by April 15 or interest will be charged starting from April 15.

 

 

[TallGuyJohninBKK]

1 hour ago, Pib said:

 

https://www.irs.gov/individuals/international-taxpayers/taxpayers-living-abroad

 

I'm seeing that the extended filing date for foreign residents this year (from the later than usual April 18 regular filing deadline this year) is going to be June 15, and then further extension date beyond that is going to be Oct. 16.

 

 

https://www.irs.gov/individuals/international-taxpayers/u-s-citizens-and-resident-aliens-abroad-automatic-2-month-extension-of-time-to-file

 

 

Quote

 

U.S. Citizens and Resident Aliens Abroad - Automatic 2 Month Extension of Time to File

 

You may be allowed an automatic 2-month extension of time to file your return and pay any federal income tax that is due. You will be allowed the extension if you are a U.S. citizen or resident alien and on the regular due date of your return:

• You are living outside of the United States and Puerto Rico and your main place of business or post of duty is outside the United States and Puerto Rico, or
• You are in military or naval service on duty outside the United States and Puerto Rico

If you use a calendar year, the regular due date of your return is April 15, and the automatic extended due date would be June 15. If the due date falls on a Saturday, Sunday, or legal holiday, the due date is delayed until the next business day.

Even if you are allowed an extension, you will have to pay interest on any tax not paid by the regular due date of your return.

How To Get The Extension

To use this automatic 2-month extension, you must attach a statement to your return explaining which of the two situations listed earlier qualified you for the extension.

 

 

 

 

Edited April 9, 2017 by TallGuyJohninBKK

[TallGuyJohninBKK]

Quote

So when the dust settled the old FBAR NLT of 30 June has been stretched out 3.5 months to 15 Oct.   Although the original intent was to put the FBAR due date in sync with your federal return NLT date of mid April, the confusing/conflicting wording ended up stretching out the FBAR date.  Our Congress and Administration/Treasury at work...guess they ought to proof read what they write before being passed into law.

 

Let's see if I've got this right.

 

The feds set out to move UP the original FBAR deadline date from the end of June to a new date of April 15 (or the next business day thereafter in the event of weekends or holidays) to coincide with the federal tax filing deadline.

 

But then they added an automatic, not only upon request, 6 month filing extension on an ongoing basis (not just the first year) that actually pushes BACK the end deadline to October 15 (or the corresponding business day thereafter).

 

So just who's the crazy ones in the house these days....

[Pib]

47 minutes ago, TallGuyJohninBKK said:

 

Let's see if I've got this right.

 

The feds set out to move UP the original FBAR deadline date from the end of June to a new date of April 15 (or the next business day thereafter in the event of weekends or holidays) to coincide with the federal tax filing deadline.

 

But then they added an automatic, not only upon request, 6 month filing extension on an ongoing basis (not just the first year) that actually pushes BACK the end deadline to October 15 (or the corresponding business day thereafter).

 

So just who's the crazy ones in the house these days....

Yeap.  I remember last year when the story first came out about the wording of the law.   The law change was actually initiated by the U.S. Treasury but somehow it got "modified" in a Congressional committee markup.  Probably Congress trying to satisfy both the Treasury Dept and  U.S. folks with foreign accounts.   Congress basically said, "OK, Treasury we'll give you your mid Apr date but you must also provide easy/automatic extensions....up to you how you how you handle that extension process part." 

 

Treasury said, "Crap!....we are between a rock and hard space....going to be confusion and more work for us unless we just give an automatic extension to 15 Oct."   We'll suck it up for now and just go back to Congress in the future, try to insert some corrected language in some bill going through Congress, do our best to proof read, and try to ensure some Congress person doesn't do a last minute markup messing the language up again before going for the final vote.  

 

Personally, I don't have an issue with the govt doing the FBAR process but their $10K figure is just too low....they haven't modified in in  decades/since FBAR became a requirement.  Heck, on your federal tax return where you have to declare any foreign assets over a certain amount, the amounts to trigger that reporting is much higher depending on your filing status...such as over $50K for filing as a single person...over $100K as a joint return if you live within the U.S.  But live outside the U.S. like say us expats in Thailand it's over $200K for a single person return and over $400K for a joint return.  

 

I need to do the FBAR each year due to the $10K amount since I keep more than that in Thai bank accounts, but not on my federal return which I file jointly with my wife which gives us a BIG $400K trigger level....sorry, I'm never going to have $200K or $400K in Thailand....not this lifetime.   

 

You would think the govt could set a common levels for the FBAR and federal return....but Noooooooo....apparently not.  See a comparison of the different trigger amounts at below IRS webpage.

Comparison of Tax Return Form 8938 and FBAR Requirements

https://www.irs.gov/businesses/comparison-of-form-8938-and-fbar-requirements