2015 FBAR Reporting Extension for Public Company Employees

On December 9, 2015, the Financial Crimes Enforcement Network (FinCEN) issued FinCEN Notice 2015-1 providing certain filers of FBARs (described below) an extension of time until April 15, 2017, to file their reports for 2015 and prior years covered by FinCEN Notices 2011-1, 2011-2, 2012-1, 2012-2, 2013-1 and 2014-1. The extension comes in light of questions FinCEN continues to receive regarding the exceptions in prior notices.

The notice further extends the reporting for:

  1. Persons with no financial interest in a foreign account but with signature or other authority over that account; and
  2. Persons with a financial interest in, or signature authority over, a foreign financial account in which the assets are held in a commingled fund. 

Notably, the issuance of the notice provides an extension to officers and employees of publically traded companies that have signature authority but no financial interest over certain foreign financial accounts. Additionally, the notice grants an extension to persons that own commingled foreign funds such as hedge funds, venture capital funds and private equity funds.

This extension does not apply to persons that own foreign financial accounts that include regulated investment companies such as mutual funds. Furthermore, the extension does not provide relief to file prior-year FBARs for specified foreign financial accounts that are not listed above. In the event that prior-year FBAR returns have not been filed in a timely manner, programs such as the Offshore Voluntary Disclosure Program or Streamlined Filing Compliance Procedure exist to help alleviate the heavy penalties and interest individuals could face for noncompliance. 

Contact us if you have questions or concerns surrounding your FBAR reporting requirements and visit our International blog to read other Schneider Downs articles

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