Friday, March 4, 2016

Proposed FinCEN Rulemaking for Rules on FBAR Reporting for Financial Professionals (3/4/16)

FinCen has released proposal revisions to rules for FBAR reporting for financial professionals.  The press release is here and the proposed changes are here. As summarized in the press release:

The NPRM [Notice of Proposed Rulemaking] proposes to:

  • Remove the provisions that limit the information reported with respect to situations when a filer has 25 or more foreign financial accounts, and instead require all U.S. persons obligated to file an FBAR to report detailed account information on all foreign financial accounts for which they are required to file an FBAR.
  • Amend the FBAR regulation by eliminating the requirement for officers and employees of institutions to report on institutional accounts for which they have signature authority, but no financial interest, due solely to their employment, so long as their employer has an FBAR filing obligation.
  • Require institutions to maintain a list of all officers and employees with signature authority over those same accounts; this list would be made available to FinCEN and law enforcement upon request.

Those interested in this subject having access to Tax Notes Today might want to read the TNT article:  Andrew Velarde, FBAR Changes Try to Balance Compliance Burden, Enforcement , 2016 TNT 42-3 (3/3/16).  I don't have permission to post it here.  I don't plan address the changes further because of demands on my time and my belief that this area of the broader subject is not of particular interest to the mainstream readership of this blog.

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