DEADLINE: Foreign Bank Account Reports Due June 30, 2016

Any U.S. person who has a financial interest in or signature authority over one or more foreign financial accounts with an aggregate value over $10,000 (on any day of the year) must report the accounts to the Treasury Department in Detroit by filing Financial Crimes Enforcement Network (FinCEN) Form 114 (the so-called FBAR) by June 30 of the following year. Thus, the deadline for 2015 FBAR filings is June 30, 2016.

The FBAR is not filed with the filer’s federal income tax return, on which a taxpayer must separately report his or her foreign financial assets. It is an annual report to the Treasury Department that, for 2015, must be filed electronically on or before June 30, 2016. No extensions of time to file are granted. An FBAR filed on Friday July 1, 2016, will be deemed late. Reporting foreign financial assets on a Form 8938 as part of the filer’s 2015 federal income tax return does not eliminate the requirement to file an FBAR.

Note: in 2017 the FBAR deadline for filing the 2016 FBAR will be April 15th (or October 15, 2017 if a six-month extension has been requested). No extension is permitted for 2015 FBARs.

E-filing is quick and secure. E-filers will receive an acknowledgement of the submission. FBARs must be e-filed at
http://bsaefiling.fincen.treas.gov/main.html.

Account holders who fail to file FBARs may be subject to civil penalties, criminal penalties or both. Those who failed to file in prior years face particular concerns which should be addressed on a case by case basis, particularly if income from those accounts was not reported on federal income tax returns.