FBAR - Guidance permits individuals to file separate FBARs for corporate and personal accounts 

March 18:  The Treasury Department’s Financial Crimes Enforcement Network (FinCEN) recently revised its BSA E-Filing System website to permit individuals with signature or other authority over their employer’s foreign financial accounts to report such accounts separately from any personal financial accounts the individual is required to report.

Reporting of a U.S. person’s financial interest in, or signature or other authority over, a foreign financial account is required on FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR)—previously Form TD F 90-22.1.

Separate FBARs permitted

The revised FBAR rule, from prior years, likely stems from the fact that all FBAR filings must now be done electronically.

The modified rule—permitting more than one FBAR to be filed by an individual—is found in a list of “frequently asked questions” (FAQs) on the BSA E-Filing System website.

Read FBAR FAQ #7 [PDF 218 KB]

Note that individuals can authorize their employer to file an FBAR on their behalf reporting the accounts over which the individual has authority by providing FinCEN Form 114a, Record of Authorization to Electronically File FBARs, to their employer.

To file on behalf of an employee, the preparer/filing entity must be registered with FinCEN’s BSA E-Filing System.

U.S. persons with a calendar year 2013 FBAR requirement must electronically file FinCEN Form 114 by June 30, 2014.

Extended filing date

Earlier this year, FinCEN issued Notice 2013-1 [1.4 MB] further extending the filing date for FBARs for certain individuals who have only signature authority over certain foreign financial accounts to June 30, 2015.

Read TaxNewsFlash-United States: FBAR filing deadline extended for the fourth time for certain individuals having only signature authority (January 15, 2014)

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