The IRS has published an FBAR Reference Guide that clients will find helpful in explaining various aspects of the Foreign Bank Account Reporting regime, including key definitions and requirements. FBARs for due no later than 30 June for the prior calendar year and must be filed electronically. Paper forms are no longer accepted. There is no extension of the filing deadline. Please do not hesitate to contact us should you have any questions or wish to discuss your FBAR filing obligations. You can read the complete guide here.
The FBAR reference guide provides an overview of the FBAR, the purpose of the FBAR, and the general reporting requirements.
We are often asked how a US person should go about determining the maximum value of a foreign account in a given year. The FBAR reference guide clarifies that a US person can report the maximum value of an account through a reasonable approximation of the greatest value of currency in the account during the year and periodic statements may be relied upon as long as the statements fairly reflect the maximum value of the account. In other words, a US person does not have to review the account history for every second of every day to determine the maximum value of a foreign account. The FBAR reference guide also recommends that records of accounts required to be reported on an FBAR be kept for five years from the due date of the return.
The FBAR reference guide provides guidance on filing delinquent FBARs by providing that delinquent FBARs should be filed online. An explanation for non-filing of no more than 750 characters can be provided with the online delinquent FBAR filing.