2015 FBAR Reporting Extension for Public Company Employees

On December 9, 2015, the Financial Crimes Enforcement Network (FinCEN) issued FinCEN Notice 2015-1 providing certain filers of FBARs (described below) an extension of time until April 15, 2017, to file their reports for 2015 and prior years covered by FinCEN Notices 2011-1, 2011-2, 2012-1, 2012-2, 2013-1 and 2014-1. The extension comes in light of questions FinCEN continues to receive regarding the exceptions in prior notices.

The notice further extends the reporting for:

  1. Persons with no financial interest in a foreign account but with signature or other authority over that account; and
  2. Persons with a financial interest in, or signature authority over, a foreign financial account in which the assets are held in a commingled fund. 

Notably, the issuance of the notice provides an extension to officers and employees of publically traded companies that have signature authority but no financial interest over certain foreign financial accounts. Additionally, the notice grants an extension to persons that own commingled foreign funds such as hedge funds, venture capital funds and private equity funds.

This extension does not apply to persons that own foreign financial accounts that include regulated investment companies such as mutual funds. Furthermore, the extension does not provide relief to file prior-year FBARs for specified foreign financial accounts that are not listed above. In the event that prior-year FBAR returns have not been filed in a timely manner, programs such as the Offshore Voluntary Disclosure Program or Streamlined Filing Compliance Procedure exist to help alleviate the heavy penalties and interest individuals could face for noncompliance. 

Contact us if you have questions or concerns surrounding your FBAR reporting requirements and visit our International blog to read other Schneider Downs articles

You’ve heard our thoughts… We’d like to hear yours

The Schneider Downs Our Thoughts On blog exists to create a dialogue on issues that are important to organizations and individuals. While we enjoy sharing our ideas and insights, we’re especially interested in what you may have to say. If you have a question or a comment about this article – or any article from the Our Thoughts On blog – we hope you’ll share it with us. After all, a dialogue is an exchange of ideas, and we’d like to hear from you. Email us at [email protected].

Material discussed is meant for informational purposes only, and it is not to be construed as investment, tax, or legal advice. Please note that individual situations can vary. Therefore, this information should be relied upon when coordinated with individual professional advice.

© 2024 Schneider Downs. All rights-reserved. All content on this site is property of Schneider Downs unless otherwise noted and should not be used without written permission.

our thoughts on
Pillar Two is Here; Is Your Company Ready?
PCAOB’s New Standard Enhances Auditors’ Use of Confirmations
SEC Adopts New Cybersecurity Rule for Public Companies
SEC's Proposed Rules on Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure by Public Companies
Greenhouse Gas Emissions, Scope Levels, & The Future of Disclosures
E.U. Environmental, Social, and Governance Proposals under CSRD and their Impact on U.S. Companies
Register to receive our weekly newsletter with our most recent columns and insights.
Have a question? Ask us!

We’d love to hear from you. Drop us a note, and we’ll respond to you as quickly as possible.

Ask us
contact us
Pittsburgh

This site uses cookies to ensure that we give you the best user experience. Cookies assist in navigation, analyzing traffic and in our marketing efforts as described in our Privacy Policy.

×