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FOREIGN BANK ACCOUNT REPORT
(FORM TDF 90-22.1 aka FBAR)
REVIEW OF FILING REQUIREMENTS
Due Date: The FBAR due date is June 30, 2012. This is the deadline for the form to be received (not just mailed), so be sure to
mail your FBAR by June 15, 2012 at the latest to ensure timely delivery. No extensions are allowed.
Click here to download the FBAR form.
Click here to read the IRS FAQ's.
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DO YOU (OR YOUR SPOUSE) NEED TO FILE AN FBAR?
1. Each individual (taxpayer, spouse, and dependents) must make a separate determination whether he or she needs to file an FBAR.
2. Make a list of all the foreign (non-US) financial accounts that were open at any time during 2011 that are:
(a) your own separate personal account,
(b) an account that you own jointly with someone else,
(c) an account owned by a business entity (corporation, partnership, etc) or trust in which you have an over-50% direct or indirect ownership interest, or
(d) an account over which you have a signature or other control or authority, but in which you have no direct or indirect financial interest (e.g., the account of an employer or friend/relative).
"Foreign financial account" includes any non-US based:
==> bank account,
==> securities and other investment account,
==> personal pension/retirement account (but not employer-administered plans or government-administered social security and similar plans),
==> insurance policies with cash surrender value, and
==> any other financial instrument accounts.
Accounts that were open at any time during 2011 count, as do accounts that had minimal or even zero balances.
Accounts located in the United States are not relevant!
3. For each account in your list, determine the single highest balance reached by that account during the calendar year, in terms of the currency in which the account is denominated.
Then, convert non-USD amounts to USD using the rates posted at this
Treasury Department website.
You may find it convenient to use my FBAR data spreadsheet to
perform this exercise (even if you are self-preparing the form).
4. After determining the maximum annual balance for each foreign account and converting all these amounts to USD, add up all of the maximum balance figures.
If the resulting sum exceeds US$10,000, you are required to file an FBAR. On that FBAR, you must report ALL of your foreign accounts that were open during 2011, regardless
of the account balance (i.e., you must even report zero-balance accounts).
5. Each individual who is required to file a report must file his or her own report.
There is an exception for a spouse all of whose accounts are joint accounts with the other spouse. Contact me for further instruction if you have this situation.
NOTES
» Fees: To prepare an FBAR, Edelman Tax Services charges a base fee of $100, plus $25 per account reported.
Thus, the fee for a form reporting 4 accounts would be $200, and for 8 accounts would be $300.
» If you are required to file an FBAR, but intend to prepare it yourself, I still need the list of countries in which your accounts are located.
Please provide this list of countries near the top of the Int&Div sheet in my data collection spreadsheet.
» If you are engaging Edelman Tax Services to prepare your FBAR(s), please fill out the FBAR-TP and/or FBAR-SP data sheet(s) in the
FBAR data spreadsheet.
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