FBAR (Foreign Bank Account Reporting) FinCEN Form 114
The Internal Revenue Service recently updated its FBAR Reference Guide wherein some clarifications were provided:
- A US person is not just an individual. It includes corporations, partnerships, limited liability companies and estates.
- A financial account includes checking and savings accounts, securities accounts, commodity futures or option accounts, mutual or pooled funds, and more.
- Cryptocurrency reporting is not yet required but is under consideration.
- Maximum account value is calculated on any day of the year not the last day.
- Many examples were added to clarify reporting requirements for foreign accounts with financial interest and those only with signature authority.
- For joint accounts, the entire value of the account is reportable by the owners.
- Foreign holdings embedded in US retirement accounts are not reportable.
- FBAR filing due date have the same rules as Federal individual income tax returns.
- FBAR penalties are assessed on violations “per account per year or per-form per year.”