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I've Never Filed an FBAR. Should I File 2013 By June 30th?

posted Jun 28, 2014, 12:08 AM by Krozel Capital
It's 11pm and I just got off the phone with a worried US citizen living in Asia. He had read my last post about the changes the IRS made to its offshore programs just last week and he wants to go through the Streamlined Procedures. Obviously his submission will not be completed in the next few days...so the question is...should he file is 2013 FBAR by the June 30th deadline or wait to file it along with his Streamlined submission? I thought about it a bit and told him he should go ahead and file his 2013 FBAR following the instructions on the IRS website for Streamlined Filings: 

"On the cover page of the electronic form, select “Other” as the reason for filing late.  An explanation box will appear.  In the explanation box, enter “Streamlined Filing Compliance Procedures.” 
I don’t necessary think that all of the FBAR’s have to be filed at the same time for Streamlined. So this way he is still filing 2013 on time and making a submission before the July 1 FATCA implementation date (he was pretty concerned about the July 1 date). Then I will work with him to complete his returns and prior year FBAR's. For this particular client, I believe this was the correct approach and wanted to share. He files 2013 on time and gets the peace of mind he needs about the July 1 FATCA date. By no means should you take this as tax advice related to your specific situation, as it may or may not be how you should proceed. If you are just learning about the IRS offshore programs now...make sure you visit the IRS website and understand there are various programs/options. There is no 'one size fits all' when it comes to the IRS offshore programs, so make sure to read about the various options and feel free to contact me if you need help...just not so late at night :)
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