The Financial Crimes Enforcement Network (FinCEN) on December 16, 2016 issued Notice 2016-1 extending to April 15, 2018 the filing date of Form 114, Report of Foreign Bank and Financial Accounts (FBAR), for certain individuals with signature or other authority over (but no financial interest in) employer owned foreign financial accounts. In light of the fact that it has not finalized regulatory changes proposed earlier in 2016, FinCEN will provide again the extension for certain employees and officers it provided in each of the previous five years.
All other individuals with signature or other authority over foreign financial accounts and those individuals and entities with financial interest in such accounts will be required to file by the recently revised due date of April 15, 2017.
Observation: The accelerated filing due date remains April 15, 2017. A legislative change permits filers to request an automatic six-month extension until October 15, 2017. FinCEN has not established a method to request the extension and instead is simply granting extensions to all filers for this filing year. Other special income tax return filing extensions for filers living abroad do not appear to apply here.
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