Some Last Minute Help with those FBARs

It's down to the wire, folks, and there are just four more days to file your Foreign Bank Account Reports (FBARs aka FinCen 114).

Mine is done and since I like to think of myself as an honest broker, I will say that once I got out of version hell and got into the form, it was much better than in previous years.  So for the folks who clearly put in a lot of work to make it less onerous, I thank you, whoever you are.  I still hate doing it (and I still feel like I'm wasting everyone's time typing in the info for a piddly little account valued at 200 Euros) but it was better.

For those of who who are first time filers, there is a very helpful video (about 6 minutes) by Andrew Mitchel up on Youtube that takes it step by step with screenshots.



One of the most common questions that I am seeing on Facebook, message boards and email is, "Should I (or do I have to) report this or that account?"  Checking, savings and other standard accounts are obvious but there are many others that are kind of country-specific, or at least a reasonable regular person can have a legitimate question about what it is exactly. Not easy to map some kinds of accounts in one country to a category on the US side.  Where to put a plan épargne logement (PEL), for example?  This is a French savings account meant to encourage people to save to buy a house or an apartment.  Is there an equivalent in the US?  I have no idea.

I can't answer these questions but we did get some advice from the local tax office here in France about reporting in the other direction (accounts in the US).  They said, "When in doubt, report everything." So that's what we did and I think that is a very safe and conservative "rule of thumb" right now whoever you have to report to.

Finally, I had a question from a visitor to the Flophouse a few months ago whose bank asked her for proof that she was up to date on her FBAR filings.  These days we file electronically so there is proof of filing this year, but what to do about the years where we submitted the forms by mail and never got anything to confirm that they were received?  How do you prove 6 years of filed FBARs?

I got the answer recently from a tax person and it is possible.  The procedure is here, buried in the middle of this page on the IRS website:

4.26.16.3.7.3  (07-01-2008)
Filing Verification

1. Filed FBARs are entered onto the Detroit Computing Center’s Currency and Banking Retrieval System (CBRS) database. Filing can be checked by IRS personnel with CBRS passwords.
2. A CBRS printout of a filed FBAR establishes that any retained FBAR was actually filed and that the retained FBAR has the same information as the filed FBAR. CBRS printouts should be obtained for both the filer’s name and his TIN.
3. Filers can request verification of the FBARs that they filed 60 days after the date of filing. A request for verification of FBAR filing must be made in writing and should include the filer's name, Taxpayer Identification Number, and filing period. There is a $5.00 fee for verifying five or fewer forms and a $1.00 fee for each additional form. If copies are needed, the additional fee is $0.15 per copy. Checks or money orders should be made payable to the United States Treasury. The payment should be mailed to:

   IRS Detroit Computing Center, P.O. Box 32063, Detroit, MI 48232 Attn.: Verification

I hope some of the information above is useful to you.  Good luck, everyone, and I will light a candle at church on Friday and make an appeal to the Divine Mercy for all of us.

Hell, can't hurt, right?