New FBAR filing deadline

22 April, 2016

While the IRS tax return due date of 15 April for individuals remains unchanged, many other filing deadlines were recently changed in the improbable act entitled The Surface Transportation and Veterans Health Care Improvement Act of 2015 (the “Act”), including the filing date for the Report of Foreign Bank and Financial Accounts Form 114 (an “FBAR”).

In very general terms, and with certain important exceptions, US tax residents having a “financial interest” or “signature authority” (all as defined) over a foreign bank, brokerage or other financial account during a calendar year must report it on an FBAR, if the aggregate value of all such financial accounts exceeded $10,000 at any time during the calendar year.

FBARs are currently due on or before 30 June of each year in respect of the preceding calendar year. Now for calendar year 2015 the current due date remains 30 June 2016. However, for calendar year 2016, the Act changes the due date from 30 June to 15 April following the year in which an FBAR must be filed. This brings FBAR reporting into line with income tax return deadlines for individuals.

In addition, the Act provides the authority to grant a six month FBAR extension filing extension period ending on 15 October.