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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, 2010. This is the deadline for the form to be received (not just mailed), so be sure to
mail your FBAR by June 15, 2010 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 of the foreign (non-US) financial accounts (e.g., bank, securities, investment and mutual funds, foreign insurance policies with cash
surrender value, and any other financial instrument accounts) that were open at any time during 2009, that are either:
(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).
Accounts that were open at any time during 2009 count, as do accounts that had minimal or zero balances.
Accounts located in the United States are irrelevant to the FBAR.
3. Determine the single-highest maximum balance during the calendar year of each account in your list in terms of the currency in which the account is denominated.
Then, convert foreign currency (FX) amounts to USD using the December 31st exchange rate (regardless on which date the account's annual maximum actually occurred).
Contact me for exchange rates, or you can search for them here: www.oanda.com.
You may find it convenient to use the FBAR-TP or FBAR-SP sheets in my data collection spreadsheet to
perform this exercise (whether or not you ultimately choose to engage Edelman Tax Services to prepare the form).
4. After determining each foreign account's maximum balance (and converting FX amounts to USD), add up all the maximum balance figures.
If the resulting sum exceeds $10,000, you are required to file an FBAR. On that FBAR, you must report ALL of your foreign accounts (even the ones that were
always under $10,000).
5. Each individual who is required to file a report must file his or her own report.
There is one exception: if all of your reportable foreign accounts
are joint accounts held with your spouse, then your spouse may file a combined FBAR reporting those joint accounts plus any other non-joint accounts
that spouse may also be required to report. In Part III, on each Line 26, write "(spouse)" after the joint owner spouse's last name, and both spouses must
sign the report on the Page 1 Line 44 signature line.
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.
» 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
data collection spreadsheet.
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