New Changes to Report of Foreign Bank and Financial Accounts ("FBAR") - FinCEN Form 114

As you may be aware (or not) there have been recent changes to the FBAR and this is creating a bit of confusion and frustration for many Americans with overseas accounts.

If you're planning to file the Report of Foreign Bank and Financial Accounts ("FBAR"), please note that the process is now to be completed online. The form must be electronically filed through the Treasury Department's Financial Crimes Enforcement Network BSA. Additional information can be found by visiting the IRS website.

You are required to file if you:

1. Are a U.S. citizen (or were a resident of the U.S. at any time during the year)

2. You had a financial stake in or authority over a bank or account located in another country during the last year.

a. This includes brokerage accounts, mutual funds, security derivatives, and other types of financial accounts.

3. The total value of the accounts exceeds $10,000 at any point during the year.

If you fall under the above requirements, please complete and electronically submit the form directly to the Treasury Department. Please be sure to save a completed copy of the form for your own records.

Filing due date and penalties:

Please note that the Report of Foreign Bank and Financial Accounts (FBAR) is to be submitted separately from your U.S. tax return. You do not need to wait for the completion of your tax return before filing the FBAR.

If required to file, you must submit this form no later than June 30, 2014. Penalties may accrue for failure to file or failure to meet the deadline. Failure to file can result in a penalty of up to $100,000 or 50% of the account value. Failure to meet the deadline can result in a penalty of $10,000.

If you have any questions, please feel free to contact us at your earliest convenience. Our firm is on standbye to assist with the new online process.