The good news is that more people seem to be aware of the filing requirement. The bad news is all the frustration people are feeling as they try to comply. I had my own moment this morning when I tried to download the form and got this on my screen instead, "If this message is not eventually replaced by the proper contents of the document, your PDF viewer may not be able to display this type of document" and then told me to upgrade to the latest version of Adobe Acrobat Reader.
Dropped straight into version hell and my first reaction was "Well, that does not bode well..."
U.S. citizens and Green Card holders have been told that this form is very VERY important and they must do their duty and comply forthwith lest they be subject to criminal prosecution and draconian penalties (10,000 USD). People (especially first-time filers) are approaching this exercise with a great deal of trepidation. If they encounter a problem at the very beginning of the process, they are not going to find that reassuring.
Does it get better once the filer has access to the form? Not really.
There are 19 pages of instructions for how to fill it out with language like this:
"Throughout these instructions the phrase “check box” and similar wording is used toFurthermore people are reporting that help is hard to come by. A Flophouse reader left this comment:
denote checking an appropriate box in certain data items on the electronic discrete FBAR. This is deemed equivalent to instructions in the Electronic Filing Requirements to enter appropriate codes in the same data items in transmission files. For example, the requirement to check a box in Item 2 “Type of Filer” in the discrete FBAR is the equivalent of entering one of the codes A through E in “Type of Filer” in the Electronic Filing Requirements Filer Information (2A) Record. "
"Two days before the deadline, we are still lost in the maze of FBARs, 3520s, and 8938s. We have visited the local IRS office, phoned the "help" lines, and not one IRS representative will help. Never mind "can" help--they will not answer questions, will not let us speak to a supervisor, and direct us to call phone numbers we've already tried."What a mess this all is and what in heaven's name can we do about it? Well, here's one idea.
Start by documenting every glitch, every error, every incomprensible paragraph in the instructions, every request for help that went unanswered by the bureaucrats.
And then complain as loudly and as forcefully as you can to the Taxpayer Advocate Service. This is Nina Olson's shop (she's the National Taxpayer Advocate and a goddess). FBAR problems are looking a lot like a systemic issue, one that "impacts a segment of the taxpayer population. It involves systems, processes, policies, procedures, or legislation; and requires study, analysis, recommendation(s), and action to effect a positive resolution."
The TAS wants to know and has an on-line Systemic Advocacy Management System (SAMS) to capture your comments and problems so they can bring them to the attention of the IRS Commissioner and Congress. You have 2000 characters to tell them what a cluster f#$%# this is.
So let them know already.