New FBAR deadline for the 2016 tax year

Since the Bank Secrecy Act of 1970 first gave the U.S. Department of Treasury the authority to collect information on foreign bank accounts held by U.S. persons, the form and method used to report and transmit this information has gone through many changes. Currently, the information is transmitted electronically to the Department of Treasury using the Financial Crimes Enforcement Network (FinCEN) Form 114, Report of Foreign Bank and Financial Accounts (FBAR).

In a new development, the FBAR filing deadline has been amended as part of the Surface Transportation and Veterans Health Care Choice Improvement Act of 2015 (the Act) passed by the Obama administration this past summer. The changes contemplated in the Act impact FBARs for 2016 and later years. The changes do not impact the filing deadline for the 2015 FBAR, which remains due on June 30, 2016, with the ability to extend the filing deadline.

Traditionally, the FBAR has had a hard deadline of June 30 of the year following the calendar year in question. However, effective for the 2016 taxation year, the FBAR deadline will be moved forward to April 15 (i.e. the 2016 FBAR form will be due April 15, 2017). Though the date has been brought forward, there is actually relief in the fact that an extension of time to file the form is also available now. According to the Act, the new FBAR deadline is to follow the extension rules similar to those already in place for U.S. personal income tax filings (usually Form 1040). The table below summarizes the revised deadlines (effective for 2016 and later years) for individuals who are required to file an FBAR.

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