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What is F BAR and Form TD F 90-22.1

F BAR for Foreign Bank Accounts

The U.S. government requires you to report each of your foreign bank and financial accounts on Form TD F 90-22.1 if at any time during the year the aggregate value of the accounts exceeds $10,000. This requirement is commonly known as the Report of Foreign Bank and Financial Accounts or F BAR.

For individuals, you only have an obligation to file a TD F 90-22.1 if you are a U.S. citizen or resident. If you fall under one of these categories, your obligation to file an F BAR kicks in if at any time during the calendar year, even if just one day, the total value of all foreign financial accounts in which you have a financial interest (or possibly only signature authority) exceed $10,000. Keep in mind that you must still file a TD F 90-22.1 even when you exceed the $10,000 threshold as a result of having multiple foreign bank accounts that separately report small cash balances. Moreover, you must evaluate the aggregate balances for each day of the calendar year; not just the balance as of December 31.

Financial Accounts to Report on TD F 90-22.1

For purposes of your F BAR compliance, the federal government defines a financial account broadly to include all savings, demand, checking, time deposit, deposit, brokerage and security accounts as well as all accounts you have for trading commodities, futures or options. The reach of the F BAR regulations even extend to insurance policies with cash values, annuity accounts and shares you hold in foreign mutual funds.

Only Foreign Financial Accounts Are Subject to F BAR

The U.S. Treasury Dept. considers your financial account to be foreign if it’s physically maintained outside of the U.S. For example, if you open a savings account at an HSBC branch in London, the account is foreign despite the fact that HSBC has a significant banking presence in the U.S. In contrast, if you open up the savings account at an HSBC branch in New York, the Treasury considers it a domestic financial account regardless of the fact that HSBC is a Chinese-based bank.

If you are subject to F BAR, you must file your Form TD F 90-22.1 with the Dept. of Treasury no later than June 30 following the close of the calendar year. However, your obligation to file TD F 90-22.1 doesn’t relate to your federal income tax return, and therefore, you should never file it with the IRS.

Reference: Form TD F 90-22.1–Report of Foreign Bank and Financial Accounts