Understanding FBAR Disclosure Responsibilities: When Must an Entity or Connected Individual File?

By: Ian Weinstock
The CPA Journal
March 2019 Edition

The Treasury Department’s Financial Crimes Enforcement Network (FinCEN) Form 114, the Report of Foreign Bank and Financial Accounts—colloquially known as FBAR— has become famous due to the huge potential penalties imposed on taxpayers whose failure to file is deemed to be willful. As a result, tax preparers know to ask whether individual clients own foreign accounts before preparing those clients’ income tax returns. But not all foreign accounts are owned by individuals. If an entity (i.e., a nonnatural person) owns a foreign account, when does the entity itself need to file an FBAR, and when does an FBAR need to be filed by someone connected to the entity?

 

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