Clarification on FBAR Filing Date Changes

Recently, we shared new information with our readers about a bill signed into law in the US that included a change in the filing due date for the FBAR, or the FinCEN Report 114, to April 15th, in line with the US Individual Income Tax return filing.

Along with that change, we also learned there would be the ability to request an extension of the FBAR filing deadline to October.

However, as the matter developed, we received clarification that these new provisions will apply to returns for tax years starting AFTER December 31st, 2015.

As a result, for taxpayers required to file a FBAR for the year 2015, the deadline will remain June 30th, 2016, as it had been previously, with no extensions possible.  

For taxpayers required to file a FBAR for the tax year 2016 and thereafter, the deadline will change to April 15th, 2017. While the possibility of requesting an extension should be available at that time, the Treasury Department has not yet provided the procedure for requesting an extension. We will certainly keep you posted in the future once we learn more.

It is important to note that the new, April 15th (2017) FBAR filing legislation will apply to all types of taxpayers, individual and corporate taxpayers alike.

A change of the FBAR filing deadline to April 15th, aligning it to the Form 1040 income tax return deadline, can certainly be seen as a positive development. Taxpayers and/or their preparers will now be able to focus on income tax and FBAR reporting at the same time and, more importantly, will be able to seek a six-month extension of the FBAR deadline if necessary.

Given the difficulties that taxpayers often experience in obtaining account records from offshore financial institutions, the ability to seek an extension will certainly be a welcome change. For our clients at BFI, we will continue to supply the needed information in January and February each year, so the eventual timeline change in 2017 will simply mean you can relax a little earlier than in the past.

With kind regards,

Bernarda Pesantez

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