NEWS FLASH: The IRS has broadened the Streamlined
Program to accept more people. See my blog on this topic here.
If you're an American living abroad, you already know that
you must report your 'foreign' (non-U.S.) financial account
to the U.S. government annually. For 2012 and prior years, this was
done using form TD F 90-22.1, separate from your tax return.
If you have a professional tax return preparer, they would
usually prepare this form along with your U.S. return. For
2011-2012, there was even some synergy with this approach, because
much of the data for the FBAR would be duplicated on form 8938,
which is actually part of the return.
The FBAR form is now obsolete. Instead, each American must file
the new form 114 – a process which can only be done online
with the ominously-named Financial Crimes Enforcement Network
(FinCEN), which also administers the Bank Secrecy Act (BSA).
Even with this new system, it is still possible to have your
preparer file the form. Unfortunately, at the time of writing this
blog, no professional tax software program is capable of e-filing
the form (several say they will have this capability later in the
year). Ultimately, a professional will do the exact same work you
would do in completing and filing the form. In fact, it will
actually be more work to provide the information to a professional
than to file it independently.
The way the system is currently set up, it will almost always
make more sense for you to do it on your own. Consequently, MNP
recommends you file your own FBAR.
1. Click the above link for the BSA website. Click the heading
"Prepare FBAR" or the link below it that reads
"FinCEN Report 114". This causes the FBAR to be
downloaded to your computer as a PDF file that you can save.
2. Fill out all relevant fields; note that every field that
appears with a pale yellow background requires a response. For most
fields, you can obtain more information about what is required by
hovering over the field with your mouse and reading the
instructions that appear.
3. Be sure to include yearly maximum balances for every account
that was open for any part of the year. Maximum account
balances need to be reported in US dollars, with currency
translated using the US Department of the Treasury's Financial
Management Service Rate for the last day of the year. Recent
rates can be found here. The IRS provides end-of-year
exchange rates for the past several years here.
4. For each category of account (Parts II through V), you can
add space for more accounts in the category within the same form by
clicking the "+" button to the right of the heading for
that account category. You do not need to fill out more than one
form per person per year.
5. For joint accounts, report the full value of the account, not
only your share. When indicating the number of joint owners, do not
count yourself. When providing information about the principal
joint owner, give information about the principal owner other than
6. When you have completed the FBAR, click the
"Validate" button on the front page of the form. You will
be informed of any errors that need to be corrected before
7. Once there are no errors, clicking the "Validate"
button will result in a request that you sign the form. To do so,
click the "Sign the Form" button on the front page of the
8. To upload your FBAR to the FinCEN website, click the
"Ready to File" button on the front page of the FBAR or
the "Submit FBAR" heading on the BSA website.
9. Enter your email address, first name, last name and phone
number and then click the "Choose File" button to browse
on your computer to the individual FBAR that you have
10. Once the FBAR is attached, you can file it electronically by
clicking the "Submit" button.
11. You should then see a message on the screen telling you that
your FBAR has been accepted. You should also receive an email
noting the acceptance of your FBAR. Both of these confirmations
will also provide a tracking ID. Save this email for your
12. Within a few days, you should receive a separate email
acknowledging your FBAR and providing a BSA Identifier. Save this
email also for your records. This completes the process of filing
13. Use the same form and follow the same instructions if you
are filing FBARs for prior years. Do not use older versions of the
form, and do not send your form by mail.
There is more detailed information available here.
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.
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