When to File an FBAR: Important Filing Deadlines

The Report of Foreign Bank and Financial Accounts (FBAR) is a mandatory disclosure for certain U.S. persons with foreign financial accounts. Its purpose is to help the U.S. government combat financial crimes, including tax evasion and money laundering, by providing information about offshore holdings.

Determining Your FBAR Filing Obligation

A U.S. person is required to file an FBAR if they have a financial interest in or signature authority over at least one financial account located outside the United States, and the aggregate value of all such foreign financial accounts exceeded $10,000 at any time during the calendar year. The term “U.S. person” encompasses a broad range of entities, including U.S. citizens, resident aliens, corporations, partnerships, limited liability companies, trusts, and estates formed in the United States.

The filing requirement is triggered by the combined maximum value of all foreign accounts. For instance, if an individual holds multiple foreign accounts, none of which individually exceed $10,000, but their total combined value surpasses this threshold at any point in the year, an FBAR must be filed. This includes a wide array of account types such as bank accounts (checking or savings), brokerage accounts, mutual funds, certain foreign-issued life insurance policies with cash value, and foreign retirement or pension plans.

To determine the aggregate maximum value, you must first identify the highest value in each foreign financial account, in its original currency, at any time during the calendar year. This maximum value can be a reasonable approximation based on periodic account statements, provided they accurately reflect the highest balance. Subsequently, each foreign currency maximum value must be converted into U.S. dollars using the Treasury Department’s Financial Management Service rate for the last day of the calendar year being reported.

It is important to note that accounts jointly owned with non-U.S. persons and accounts over which an individual has signature authority, even without a direct financial interest, may also be reportable. For example, an employee with control over an employer’s foreign bank account would need to report it. Furthermore, spouses who jointly own all their foreign financial accounts can consolidate their FBAR reporting under specific conditions, requiring one spouse to file FinCEN Form 114a authorizing the other to file on their behalf.

Key FBAR Filing Deadlines

The FBAR is an annual report with a primary filing deadline of April 15th of the year following the calendar year being reported. This aligns with the general tax filing deadline for many individuals.

However, filers who do not meet the April 15th deadline are granted an automatic extension to October 15th. This extension is granted without the need for a specific request or form submission.

If April 15th or October 15th falls on a weekend or a legal holiday, the deadline is generally shifted to the next business day. This common rule for federal deadlines helps accommodate typical calendar variations. Although the FBAR is not a tax form, its due date is often aligned with income tax return deadlines.

Submitting Your FBAR Report

Once the filing obligation has been determined and all necessary financial information gathered, the FBAR must be submitted electronically. The official method for filing is through the Bank Secrecy Act (BSA) E-Filing System, managed by the Financial Crimes Enforcement Network (FinCEN). The specific form used for this purpose is FinCEN Form 114.

Individuals filing their own FBARs do not typically need to register for a BSA E-Filing account and can file as a guest. However, tax professionals filing on behalf of clients must register.

After successful submission, the system provides a confirmation email or unique tracking number, such as a BSA ID number, which serves as proof of filing. It is advisable to retain a copy of the filed FinCEN Form 114 and this confirmation for personal records. This documentation can be important for future reference or in case of any inquiries.