May is over and June represents another filing deadline for persons who have foreign bank
accounts and investments
Some things to remember to prepare Form TD F 90-22.1, Report of Foreign Bank and
Financial Accounts, commonly referred to as FBAR, for calendar year 2011:
1. Make sure to use the most current version of the form (dated January 2012) to ensure the
filing is not rejected by FinCEN. The government does not process expired versions of this
form.
2. Calendar 2011 FBARs must be received by Treasury on or before the June 30 due date in
order to be considered timely filed. Therefore, one should plan accordingly and file the
FBAR in sufficient time in advance of the due date. No extension of time is permitted. The
familiar mailbox rule that applies for income tax returns is not applicable with respect to
FBAR.
3. For those who are able, consider the use of the BSA E-Filing system to electronically
submit the calendar 2011 FBAR. Electronic filing of FBAR is only currently available by the
actual FBAR filer, and is not yet available for practitioners to file on behalf of their clients for
calendar 2011 FBARs. All should keep in mind that FinCEN is moving forward with plans
to require mandatory electronic filing for all FBARs in the future.
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