U.S. FBAR Rule’s Wide Net

All overseas account signatories must report on personal tax forms.

The reach of the U.S. Foreign Bank Account Report (FBAR) requirement may surprise many U.S. corporate finance employees, who might assume that since they have no financial interest in the company’s overseas accounts, they’re exempt from reporting. In fact, the U.S. Financial Crimes Enforcement Network (FinCen) broadened the scope of the FBAR rule last year to include even employees with no financial interest in foreign accounts.

That means all those with control over an account or accounts with total balances of more than $10,000 are now required to check the appropriate boxes on Schedule B of their personal income tax return, then file an additional form, TD F 90-22.1, by the end of June.


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