Report of Foreign Bank and Financial Accounts

(FBAR) Due June 30, 2016

If you maintain bank or financial accounts outside the United States you may be required to file an FBAR (now known as FinCEN Form 114) by June 30th. If the maximum value of one or more of your foreign accounts exceeded $10,000 in the aggregate during 2015, you should complete and file this form or inform your accountant. As the value threshold is aggregate you could, for example, have five foreign accounts with maximum values of only $2,500 each and still be subject to the filing requirement. A qualifying foreign account is one which you have either an interest in OR signature authority over.

Noncompliance, whether willful or nonwillful, carries significant penalties. Nonwillful violations are subject to civil penalties up to $10,000, whereas willful violation penalties can be up to the greater of $100,000 or 50% of the account balance.

The FBAR must be filed electronically and is available online through the BSA E-Filing System.

Effective for tax years beginning with 2016, the FBAR filing deadline will now be aligned with the individual tax return filing deadline of April 15, 2017. In addition, a six-month extension will be available for the FBAR through October 15, 2017.

For more detailed information on the FBAR, follow this link to the IRS website: Report of Foreign Bank and Financial Accounts (FBAR)