Revenooer Rants: Foreign financial account reports due soon (opinion) |

Revenooer Rants: Foreign financial account reports due soon (opinion)

Jeff Quinn

All deadlines have more or less equal implications, but some deadlines are more equal than others. This one looms – no later than June 30 upcoming!

By law, many U.S. folk with foreign accounts exceeding certain thresholds must file Form 114, “Report of Foreign Bank and Financial Accounts” (aka “FBAR”) electronically with the Treasury Department’s Financial Crimes Enforcement Network (“FINCEN”).

Commish Koskinen recently reminded you. “Taxpayers here and abroad should take their foreign account reporting obligations very seriously,” he reminded. Check out the penalties if you don’t believe the Commish or us!

In general, the filing requirement applies to folks who had an interest in, or signature or other authority over foreign financial accounts whose aggregate value exceeded $10,000 at any time in 2015.

IRS is also on the lookout to implement the “Foreign Account Tax Compliance Act” (“FATCA”), which mandates third party reporting of foreign accounts to promote tax compliance.

Hence the need for many to file Form 8938, “Statement of Specified Foreign Financial Assets,” filed with the owner’s annual tax return. Filing thresholds for this Form are more stringent than for the FBAR.

And speaking of compliance reporting meanness, a recent IRS “Program Manager Technical Advice” makes it clear that 2015 legislation requiring IRS to enter into contracts with private debt collectors to harvest delinquent tax debt does not take away IRS’ discretion to prioritize cases most suitable for immediate action.

IRS thinks that although the language now in the Revenue Code evidences Congress’ clear intent to maximize the use of private debt collectors, it believes it nevertheless has the discretion to prioritize cases most suitable for assignment right now!


CONSULT YOUR TAX ADVISER – This article contains general information about various tax matters. You should consult your CPA regarding the implications to your own particular situation. Jeff Quinn is a CPA, recently retired from Ashley Quinn, CPAs and Consultants, Ltd., with offices in Incline Village and Reno. He welcomes comments at

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