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FBAR Extended Deadline Fast Approaching

September 27, 2022

Foreign Financial Account holders, did you miss the April 18 filing deadline for your 2021 Foreign Bank Accounts Report (FBAR)? The extended deadline is due October 17th…don’t be late.

Attention Foreign Financial Account holders: if you missed the April 18th deadline, you have until October 17th to submit your 2021 Foreign Bank Accounts Report (FBAR) to the Department of Treasury.

Who must file?

As a reminder, U.S. citizens and green card holders (including expats) are required to file an FBAR if:

  • They have financial interest in or signature authority over at least one financial account located outside the United States
  • They have financial foreign accounts with an aggregate value which exceeds $10,000 at any time during the calendar year. For example, if you have Bank account A with a value of $4,000 and Bank account B with a value of $7,000 you triggered the filing threshold.
  • It is possible to not have an income tax return filing requirement and still must file the FBAR.

Filing Instructions

If you have met the filing thresholds for the FBAR, or FinCEN 114, you will need to electronically file the FBAR by the due date.

Oops—I missed the deadline and forgot to file for an extension!

Don’t worry--you do not need to specifically file for or request an extension as the Financial Crimes Enforcement Network (FinCEN) grants filers failing to meet the April 18th due date with an automatic extension to October 17th this year.

What are the penalties?

If you fail to file, remember that you are subject to either a civil penalty of up to $10,000 for each negligent violation (non-willful violation), or a civil penalty of up to $100,000 or 50% of the balance of the account at the time of the purposeful violation (willful violation). Criminal penalties can arise as well for willful violations.

Questions? Contact any member of our International Tax Services Practice.

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