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  • Daniel Gray CPA Toronto

FBAR Fincen 114 - the easy guideline


STREAMLINED FILERS: For each of the most recent 6 years for which the FBAR due date has passed, file delinquent FBARs according to the FBAR instructions - the full line by line PDF instructions and e-file PDF instructions are below. Just click on either of the below snapshots PDF cover pages to pop-up the full PDF instructions.You are required to electronically file FBAR - whether delinquent or not - at FinCen's website.

STREAMLINED FILERS: for reason for filing late in the FINCEN 114 online drop-down menu select“Other”and type in the explanation box that appears: “Streamlined Filing Compliance Procedures.”

Trick/Tip: create the first year (say, 2010) and save it on your computer as, say, PDF2010 BUT DON’T CLOSE THE INTERNET PAGE ON THE FINCEN SITE. Then, using the same online pages already populated with all your info, just update that info to the next year, say 2011, with new 2011 info such as maximum amounts. Many of your accounts will be the same from year to year, so, using this trick/tip process will save you the trouble of separately re-entering all that info six times for streamlined. Then save that PDF as, say, PDF2011 – be careful that you rename the new file when saving it and do not mistakenly overwrite the previous year file (ouch!). You’ll end up with the six years of Fincen 114 forms saved on your computer, all of which you can then submit online.

Tech Tip: Fincen site has problems with Chrome browser. As well, one needs Adobe Reader, having Adobe but without the reader also installed won't work.

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Three potential scenarios for applicable IRS procedures include:

If you file FBAR via streamlined before the 2017 due date for 2016 starts, you’d file 2010-2015 “For each of the most recent 6 years for which the FBAR due date has passed, file delinquent FBARs according to the FBAR instructions and include a statement explaining that the FBARs are being filed as part of the Streamlined Filing Compliance Procedures. You are required to file these delinquent FBARs electronically at FinCen.”

Amended prior year returns can be filed as part of streamlined: “if a U.S. tax return has been filed previously, submit a complete and accurate amended tax return using Form 1040X, Amended U.S. Individual Income Tax Return, together with the required information returns (e.g., Forms 3520, 5471, and 8938) even if these information returns would normally be filed separately from the Form 1040 had the taxpayer filed a complete and accurate original return.”

What about catching up only on FBAR but not on 1040s? The answer is here: https://www.irs.gov/individuals/international-taxpayers/delinquent-fbar-submission-procedures “Taxpayers who do not need to use either the OVDP or the Streamlined Filing Compliance Procedures to file delinquent or amended tax returns to report and pay additional tax, but who: have not filed a required Report of Foreign Bank and Financial Accounts (FBAR) (FinCEN Form 114), are not under a civil examination or a criminal investigation by the IRS, and have not already been contacted by the IRS about the delinquent FBARs should file the delinquent FBARs according to the FBAR instructions.


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