Meet your evolving needs with three integrated business lines in one professional services firm.


Investment advisory services are offered through CliftonLarsonAllen Wealth Advisors, LLC, an SEC-registered investment advisor.

March 7, 2012 Tax Watch: The Treasury Department’s Financial Crimes Enforcement Network (FinCEN) announced on February 24, 2012, a general exemption from mandatory electronic filing for Form TD F 90-22.1, Report of Foreign Bank and Foreign Financial Accounts (FBAR). FinCEN has moved the deadline for mandatory FBAR e-filing until after July 1, 2013.

Treasury Defers Mandatory Electronic Filing of FBARs

  • 3/7/2012

Treasury Defers Mandatory Electronic Filing of FBARs

The Treasury Department’s Financial Crimes Enforcement Network (FinCEN) announced on February 24, 2012, a general exemption from mandatory electronic filing for Form TD F 90-22.1, Report of Foreign Bank and Foreign Financial Accounts (FBAR). FinCEN has moved the deadline for mandatory FBAR e-filing until after July 1, 2013.

Electronic Filing

United States persons who have a financial interest in, or signature authority over, a foreign financial account may be required to file an FBAR. No report is required if the aggregate value of the accounts does not exceed $10,000.

In 2011, FinCEN proposed to mandate e-filing of certain reports required under the Bank Secrecy Act, effective June 30, 2012. Included among those reports was the FBAR.

When FinCEN proposed mandatory e-filing, the agency observed that it had expanded its support of electronic filing to individuals. FinCEN reported that individuals may sign up to file their individual FBARs by accessing the agency’s e-file website.

“The proposal last year did not distinguish among the type of FBAR filer,” Michelle Koroghlanian, CPA, technical manager, American Institute of Certified Public Accountants (AICPA), told CCH. “The language released on February 24 also does not distinguish among the type of FBAR filer,” Koroghlanian observed.

FBAR Exemption

FinCEN has now provided a general exemption to mandatory e-filing of the FBAR until July 1, 2013. FinCEN cautioned that the temporary exemption does not relieve filers of the obligation to file an FBAR. The exemption also does not affect the required date the FBAR must be received. Thus, calendar 2011 FBARs are still due by June 30, 2012; the filing can be on paper or electronically. Earlier in February, FinCEN extended the FBAR filing deadline for certain financial professionals.

Koroghlanian told CCH that the AICPA has voiced concerns about mandatory FBAR e-filing, noting that some individuals may only have access to the Internet at a public facility, such as a library, and using a public computer could raise questions about privacy.

Other Reports

FinCEN also announced that it may provide a limited number of exemptions from mandatory electronic filing for filers of other reports. Unlike the FBAR exemption, there is no general exemption for these reports. Rather, filers must apply for an exemption and show a substantial hardship in meeting the e-file mandate.

©2012 CCH. All Rights Reserved.