# Streamline Filing what is thew answer on Schedule B



## Kph100 (Jul 23, 2018)

Currently about to file back tax forms under the streamline Procedure and have to complete Part 3 of the schedule B to state have foreign bank account.

The next tick box is are you required to fill FINCEN 114 form. Well normally the answer to that is NO because below the $10,000 notification limit, however under the streamline procedure you have to file 6 years of FBAR / FINCEN forms regardless of it below the 10k or not.

So what do we put on the schedule B, Im thinking if tick yes then the IRS will assume we have more than $10,000 in a foreign account and think we should be earning interest on it then we dont, and will be putting interest income as nil on the 1040.

Advice please.


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## Bevdeforges (Nov 16, 2007)

You can probably go either way. Just be prepared to explain your position should anyone ever come back to you to ask (which they almost never do).

Are you required to file a FinCEN 114 - if the total of your foreign bank accounts doesn't reach $10,000 then check "no." That doesn't mean you won't file the back forms as part of your Streamlined filing (or not - however you choose to do it). They really don't match up tax returns with FinCEN filings unless something very "odd" turns up on your tax returns.

But it sounds to me like "no" is the correct answer. But file the back forms for the Streamlined program anyhow if they insist. There are plenty of foreign bank accounts that don't pay any interest at all.
Cheers,
Bev


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## Kph100 (Jul 23, 2018)

im still a little confused. I initially thought had to submit 6 years FBAR reports for streamlined procedure even if under $10,000 limit

but i have also read only need to acknowledge that requirement and if under $10k dont need to submit them 

Which is correct ?


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## Bevdeforges (Nov 16, 2007)

I don't think it's really an either-or situation. US tax rules (and law) are subject to interpretation. 

If it says somewhere in the instructions for the Streamlined program that you MUST submit the FinCENs even if you don't meet the requirements, then do so. If it doesn't say so in the instructions, then you're at liberty to claim that you are not required to file and simply not to do so.

If you choose to file them, just to show them that you're not required to file, then that's a viable option, too.
Cheers,
Bev


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