Tom Hunt, Director of Treasury Services, AFP
Until this year, the Report of Foreign Bank and Financial Accounts (FBAR) filing date has been June 30. That was changed this year to the individual tax filing date, in conjunction with the Surface, Transportation and Veterans Health Choice Improvement Act. This year, that date is April 18 because Tax Day was pushed back a few days, but thereafter it will be on the usual date of April 15.
If that date feels like it’s coming too fast, you may not need to worry this year. The Financial Crimes Enforcement Network (FinCEN) and the Internal Revenue Service (IRS) are granting all taxpayers a six-month extension every year. So you really have until October 15. You don’t have to ask for the extension; it’s automatically granted.
That extension may remain in effect next year and beyond. But if not, treasurers could be forced to file two and a half months earlier than they are used to.
Additionally, once again, employees and officers of specified regulated entities who have only signature authority over certain financial accounts but no interest in them have been granted a one-year extension. This has been done every year since 2010. Most treasurers I’ve talked to haven’t required these extensions, but they are there if you do need them.
What to do
With these new FBAR regulations in place, treasury departments are going to have to make some changes going forward.
Start the process sooner. There’s no guarantee that FinCEN will keep that six-month extension intact next year. So even if you wait until October to file in 2017, keep in mind that may not be an option in 2018 or 2019.
Determine which of your employees could get the one-year extension. You may have staff members who qualify for the one-year filing extension if they only have signature authority.
Read AFP’s FBAR Guide. In 2015, members of AFP’s Treasury Advisory Group spoke with FinCEN and the IRS over the confusion many treasury professionals had over complying with FBAR regulations and compiled the interviews in a helpful guide. There’s a lot of good information in there that can help you if you’re filing for the first time. The guide is available here.