Technical Tax Blog


International Tax - Current FBAR Guidance


The FBAR form filing date will be aligned with annual income tax filing deadline of April 15 starting in tax year 2016.

On July 31, 2015, President Obama signed a three-month highway funding extension bill called “The Surface Transportation and Veterans Health Care Choice Improvement Act of 2015” (H.R. 3236, Pub.L. 114-41). Under the new legislation, the due date of FinCEN Form 114 (known as the “Foreign Bank Account Report” or “FBAR”) will be April 15 instead of June 30 and filers will be able to seek a six-month extension of the deadline. Similar to individual income tax returns, US citizens residing abroad will receive an automatic extension of time to file the FBAR until June 15, with an additional four-month extension available to October 15.

Essentially, the new legislation conforms the due date of the FBAR to the individual income tax return filing deadline. Under prior law, the FBAR filing deadline was June 30, and no extension was available.

The new deadline applies to FBARs for taxable years beginning in 2016. As a result, for filers required to file the FBAR for 2015, the deadline will remain June 30, 2016. For filers required to file an FBAR for 2016 and thereafter, the deadline will be April 15 following the end of the calendar year.  See FinCEN Notice 2016-1.

The IRS will not impose a penalty for the failure to file the delinquent FBARs if income from the foreign financial accounts reported on the delinquent FBARs is properly reported and taxes are paid on your U.S. tax return, and you have not previously been contacted regarding an income tax examination or a request for delinquent returns for the years for which the delinquent FBARs are submitted. If you have questions about the new FBAR updates and need help with such reporting, please contact Jason Bitner by email at or by phone on 08 9330 8790 or 0488 020 286.