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International Tax Bulletin (August 2015)

FBAR Filing Deadline Revised



By Brian Wainwright, a tax partner in the Palo Alto office of Pillsbury Winthrop Shaw Pittman LLP.

If you have or can obtain the Acrobat Reader, or have an Acrobat-enabled web browser, you may wish to download or view our August 2015 International Tax Bulletin (a 218K pdf file), containing a printed version of this article and also available via ftp at:

    ftp.pmstax.com/intl/bull1508.pdf.

This bulletin concerning tax matters is part of the Tax Page, a World Wide Web demonstration project, no portion of which is intended and cannot be construed as legal or tax advice. Comments are welcome on the design or content of this material.

Reports of foreign bank and financial accounts (FinCEN Form 114(a), formerly Form TD F 90.22-1 and commonly referred to as FBARs) for 2016 will be due April 15, 2017 but with an available extension until October 15, 2017. FBARs for 2015 will continue to be due June 30, 2016 without the possibility of any extension. Technically, section 2006(b)(11) of the recently enacted Surface Transportation and Veterans Health Care Choice Improvement Act of 2015 (P.L. 114-41) directs Treasury to modify appropriate regulations to provide, for returns for taxable years beginning after December 31, 2015, that the due date for FBARs shall be April 15 with a maximum extension for a six-month period ending on October 15.

No change has been made to the requirement that individuals file their FBARs electronically. However, Treasury has added an alternative to the online form giving individual filers the ability to download a pdf version of the form for offline completion using Adobe Acrobat and upload of the completed form. See the material at


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