FBAR Requirement: In simple terms, US Citizens and resident aliens (i.e. anyone filing Form 1040) are required to report Foreign Financial Accounts in FBAR form if Value of their Foreign Financial Accounts (FFA) (including bank, FD, shares, securities, mutual fund, cash value of life insurance, etc.) exceed $10,000 at any time during the calender year so that the form is received by Department of Treasury by June 30.
COMMON INFORMATION REQUIRED FOR FBAR COMPLIANCE
FFA Owned Independently (Part II), Jointly (Part III), Signatory Authority (Part IV)
| No. per FBAR Form | Information on Financial Account(s) Owned Separately |
| 1-14 | Basic info about Form Filer (Name, SSN, DOB, US Address, etc.) |
| 6-8, 26-28, 34,36,37 | Owner Name (independent, principal, owner) (Last Name, First Name, Middle Initial) |
| 15 | Maximum value of account during calendar year reported (in USD) |
| 16 | Type of account |
| 17 | Name of Financial Institution in which account is held |
| 18 | Account number or other designation |
| 19, 29, 38 | Mailing Address (Number, Street, Suite Number) of financial institution in which account is held (financial institution, principal, owner) |
| 20, 30, 39 | City (financial institution, principal, owner) |
| 21, 31, 40 | State, if known (financial institution, principal, owner) |
| 22, 32, 41 | Zip/Postal Code (financial institution, principal, owner) |
| 23, 33, 42 | Country (financial institution, principal, owner) |
| 24 | No. of Joint Owners of financial accounts |
| 25, 35 | Taxper ID of Principal Joint Owner of financial account |
| 43 | Filer’s Title with its owner of financial account |
Additional Information on FBAR:
| 1. FBAR: http://www.irs.gov/businesses/small/article/0,,id=148849,00.html |
| 2. FBAR Rule: http://www.gpo.gov/fdsys/pkg/FR-2011-02-24/pdf/2011-4048.pdf |
| 3. FBAR Form TD F 90-22.1: http://www.irs.gov/pub/irs-pdf/f90221.pdf |
| 4. FAQs on FBAR: http://www.irs.gov/businesses/small/article/0,,id=148845,00.html |
| 5. Webinar on FBAR: http://www.irsvideos.gov/ReportingForeignFinancialAccountsOnTheFBAR/ |
| 6. Comparison between 8938 and FBAR: Source: http://www.irs.gov/businesses/article/0,,id=255986,00.html |
Comments
Maya
Hi,
If I have 5 NRE FD with the same bank, do I have to report them separately or I can total them up and report it on FBAR?
Jigar Patel, CFA (USA), MBA-Finance (USA), CPA (USA), CA (India)
You may aggregate all your accounts in one bank and report by your unique customer code for the bank. However, as the FDs would have a unique FD account number, you may also report them separately. In short, there need to be a unique identifying number that is attached to your account. Thanks.
Priya
Hi Jigar,
I have become an NRI this year. I have opened NRO & NRE Savings Accounts (in 2 banks in Dec 2014) and transferred all my FDs (from various resident accounts – around 6 banks) to the NRO account of one bank in December 2014. I am in the process of closing all savings accounts with these banks. But for FBAR (Jan to Dec 2014) will I have to report all 6 foreign bank accounts or only those 2 new NRO/NRE bank accounts? Also what will be the maximum value of FD + Savings Account? How do I determine that? There are numerous FD’s so its best to put the customer id instead of the FD Account Numbers…will that be ok?
Also according to point 14a of FBAR form…I don’t have more than 25 Bank Accounts but I had more than 25 FD’s in the 6 banks…Should I check yes or no?
Need your kind advice on the above matter
Jigar Patel, CFA (USA), MBA-Finance (USA), CPA (USA), CA (India)
For FBAR, you would report all your accounts – residents as well as NRO/NRE. Yes, it may result in duplicate reporting. For reporting in FBAR a unique ID is important. While you may have many different FD account, you would have a unique customer ID. You may report your investments by customer ID.
Priya
Dear Jigar,
Thanks for your reply. There are few more questions I would like to ask
1) Do I have to get bank statements for maximum account value…since I don’t have online account with these banks?
2) Also for point 14a should I check no…since I don’t have more than 25 banks?
3) Also for next q do u have signing authority or financial interest? Does financial interest mean first name?
4) I have emailed the three life insurance cos for the surrender value…if they don’t give can I check maximum value unknown?
5) Guess I have to report my Ppf balances too
6) I have joint accounts 2nd name with my mom some are former survivor, some are either survivor and some are nominee. Which ones do I report? Should I delete my name to avoid further reporting. Also if I delete it now will I still have to report for 2014 and 2015? (Since I deleted in Jan/Feb)
7) Does the amounts in 2nd name joint account with mom count for Form 8938 reporting?
Some things are quite confusing….your blogs have given me quite a bit of clarity…but this is going to be a very tedious task…getting amounts while in USA
Awaiting your reply,
Jigar Patel, CFA (USA), MBA-Finance (USA), CPA (USA), CA (India)
As per FBAR requirement, all your financial accounts e.g. Bank, FD, PPF, Demat, Life insurance, etc. needs to be reported. Form 8938 requires to report the foreign financial assets and related income. Through this blog, we serve NRIs by educating and providing general information and clear their doubts on NRI investments and taxation in India. For detailed instructions filling of form, please contact your CPA or us. Thanks.