# US Tax Returns



## sp84

Good afternoon everyone, 

I am from the UK originally, but lived in the USA for 4 years, becoming a US citizen and then moving back to the UK in the middle of 2016.

As all other US citizens will know, tax filing season is upon us. Due to my very (very!) limited knowledge of the US tax system, I was looking into having a professional that deals it US expat taxes. There are several based in the USA - the likes of taxes for expats and Bright!Tax. I have emailed them and received a quote. 

I was just curious if anyone on here had used these companies before and could maybe tell me what they thought.

Or if you think it would be better to use a UK based company/accountant ? If so, any recommendations about who to use?

My tax returns should be relatively straight forward, but I would rather pay to make sure that they are done right (and to give me some peace of mind).

Thanks!!!


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## Bevdeforges

It might be best if we moved this over to the Expat Tax forum. Many of the most "popular" tax preparation services for US taxpayers tend to be online these days, so location isn't all that important.

The other option is to look into using one of the tax preparation software (do-it-yourself) - like TurboTax, TaxAct or H&R Block. There is also the IRS Free File program - https://www.irs.gov/uac/free-file-do-your-federal-taxes-for-free - which will at least give you a listing of the various online tax preparation options that are available. (Even if you wind up having to pay for the software - it's still cheaper than using an accountant.)

Don't forget, too, that US returns don't have to be "perfect." In fact, there is no one "correct" way to file any particular tax situation. Everything is subject to interpretations and nuances, particularly when you have foreign source income in the mix.
Cheers,
Bev


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## sp84

Bevdeforges said:


> It might be best if we moved this over to the Expat Tax forum. Many of the most "popular" tax preparation services for US taxpayers tend to be online these days, so location isn't all that important.
> 
> The other option is to look into using one of the tax preparation software (do-it-yourself) - like TurboTax, TaxAct or H&R Block. There is also the IRS Free File program - https://www.irs.gov/uac/free-file-do-your-federal-taxes-for-free - which will at least give you a listing of the various online tax preparation options that are available. (Even if you wind up having to pay for the software - it's still cheaper than using an accountant.)
> 
> Don't forget, too, that US returns don't have to be "perfect." In fact, there is no one "correct" way to file any particular tax situation. Everything is subject to interpretations and nuances, particularly when you have foreign source income in the mix.
> Cheers,
> Bev


Thank you so much Bev!

One person that I spoke to suggested that I used a UK based accountant because they would be governed by UK tax law. Apparently it is illegal to offer tax advice here if you are not qualified/know what you are talking about & apparently the same regulations don't apply to US based companies 

I know that taxes for expats and Bright!Tax are mainly based online, but they seem to have a good response time/communication through their customer service team - and even have a UK phone number if you need to speak to someone.

My problem is that I don't understand (or know all of the nuances/things to use to my advantage)- especially relating to taxable income, days inside and outside of the USA, tax credit etc, that is why I am hoping to use a professional (even though I will pay for it).

You said it would be best if this was moved to the Expat tax forum? Is that within this particular site? or a completely different site? Should I re-repost my original post?

Cheers!


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## iota2014

sp84 said:


> Thank you so much Bev!
> 
> One person that I spoke to suggested that I used a UK based accountant because they would be governed by UK tax law. Apparently it is illegal to offer tax advice here if you are not qualified/know what you are talking about & apparently the same regulations don't apply to US based companies


Tax accountants in the UK are quite heavily regulated (ICAEW as a regulator | Act in the public interest | ICAEW) but I'm not sure that includes getting you the lowest-possible tax-payable outcome with the IRS. If they advised you _wrongly_ (for instance, advised you to claim tax relief you weren't entitled to, thus getting you in hot water), you might well have grounds for a complaint, but if they advised you _incompetently_ (which is much more likely), you might not even realize that you weren't getting the best advice.

The advantage of doing it yourself is that you can make sure you're not paying more than necessary, and you end up understanding exactly what you've filed.


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## Bevdeforges

I've already moved this thread to the Expat Tax forum. The fact that you were able to ask the question means that somehow you found your way here/there.

There are two publications you may want to take a look at. https://www.irs.gov/uac/about-publication-54 and https://www.irs.gov/uac/about-publication-17

Both are rather long so you may prefer to scan them online and then only download or print out those sections that relate to you. But Pub 54 is everything you need to know as an "overseas" taxpayer, while Publication 17 is your basic guide to nearly everything you might want to know about US taxes. (Or at least where to find out anything not covered in sufficient detail in Pub 17).
Cheers,
Bev


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## horseshoe846

iota2014 said:


> The advantage of doing it yourself is that you can make sure you're not paying more than necessary, and you end up understanding exactly what you've filed.


That is the argument my wife makes - for having me file our own return. Only trouble is - the day I put last year's return in the mail I had a good understanding of what I had filed - but today, a year later, I don't remember quite as well.


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## sp84

iota2014 said:


> Tax accountants in the UK are quite heavily regulated (ICAEW as a regulator | Act in the public interest | ICAEW) but I'm not sure that includes getting you the lowest-possible tax-payable outcome with the IRS. If they advised you _wrongly_ (for instance, advised you to claim tax relief you weren't entitled to, thus getting you in hot water), you might well have grounds for a complaint, but if they advised you _incompetently_ (which is much more likely), you might not even realize that you weren't getting the best advice.
> 
> The advantage of doing it yourself is that you can make sure you're not paying more than necessary, and you end up understanding exactly what you've filed.


Thank you everyone (and thank you for the IRS publications Bev) ! 

I 100% agree about doing the returns myself and understanding it better (especially for future tax returns), which I suppose is why I have been leaning toward having someone like Taxes for Expats do it for me.<snip>

Their process, from what I understand, involves me filling out a questionnaire (financial information etc) and then they complete the tax return on the basis of that. While at the same time, asking me the necessary questions to make sure that I have not left anything out. 

I am hoping that by going through the process with them - and seeing the end result in my tax return, that in the future I will have a much better idea about how to file myself.

Taxes for expats have a 9.8 out of 10 on UK Trust Pilot & because they are based in the USA, I assume they know their stuff. My situation is slightly complicated because I moved from California - one of the most notoriously difficult states to leave (tax wise). They can apparently chase you down forever for unpaid tax, so I want to make sure I cut ties properly with them in this return. 

My wife and I recently had a baby & feel overwhelmed as it is - so between that and work - I have no idea where I am going to find the time to get my head around understanding everything and filing correctly, by April 15th. And that is just with the tax returns themselves, not to mention FBAR and FACTA  my understanding at the minute is extremely basic. Having lived in the UK most of my life, where I have never had to look at, never mind file a tax return.

The individual that I had spoken to (that advised me to use a UK based accountant) said the following:

_...for most UK based individuals there are often considerable advantages in having a UK based adviser who can jointly advise on both US and UK tax issues and (possibly) handle both sets of tax returns in the UK.

These include:
1. The client and the adviser being located in the same time zone.
2. Client documents and workpapers being held outside of the United States; which many people perceive as providing additional protection in the event of IRS audits.
3. Advisers outside of the UK are unable to offer the protections to clients provided by the UKs Proceeds of Crime Act, which requires all tax professionals offering services in the UK to be regulated and supervised for anti-money laundering protection purposes. Here in the UK it is a criminal offence to offer tax advice unless the adviser is supervised. Quite unlike within the UK, there is no requirement for mandatory regulation of tax advisers in most of the United States. 
4. The fact that although there are roughly one million paid tax professionals within the United States, that there are naturally only very few amongst these who understand enough about the US reporting of foreign based taxpayers.
5. Most tax advisers outside of the UK are not bound by the UK ethical standards that govern UK qualified advisers; which set out fundamental principles of integrity, objectivity, competence and care, confidentiality and behaviour (Professional Conduct in Relation to Taxation | Chartered Institute of Taxation).
6. The opportunity in the unlikely event that things ever go wrong to get issues addressed through a supervisory body that is closer to the client than an adviser located several thousand miles away._

I am curious to see what you think about that???

Also, if I do decide to go with an online company, are they any in particular that you would recommend/have maybe used yourselves? 

Thank you folks - I know I shouldn't be, but I have been having many sleepless nights lately over this.


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## iota2014

sp84 said:


> I 100% agree about doing the returns myself and understanding it better (especially for future tax returns), which I suppose is why I have been leaning toward having someone like Taxes for Expats do it for me. https://www.taxesforexpats.com/
> 
> Their process, from what I understand, involves me filling out a questionnaire (financial information etc) and then they complete the tax return on the basis of that. While at the same time, asking me the necessary questions to make sure that I have not left anything out.


I could be mistaken, but when I looked at their website, during my hour of panic, I got the impression they would just put my info into a software package, and then ask me questions about anything flagged by the software. But I expect they do indeed know their way around a tax return, as otherwise the IRS would put them on the very expensive naughty step. 



> I am hoping that by going through the process with them - and seeing the end result in my tax return, that in the future I will have a much better idea about how to file myself.


Yes, that was what I was hoping for. In the end I decided to do it myself. I grant you, my circumstances are very straightforward, and the items I wasn't sure about were exactly the items that would have cost me a lot if I had gone with TfE. So for me it was better that I did it myself.



> My wife and I recently had a baby & feel overwhelmed as it is


Congratulations!. Hang in there, they do eventually go to sleep! Exhausting though.




> - so between that and work - I have no idea where I am going to find the time to get my head around understanding everything and filing correctly, by April 15th.


 Filers abroad get an extension, if I recall correctly.



> And that is just with the tax returns themselves, not to mention FBAR and FACTA  my understanding at the minute is extremely basic.


FBAR is easy-peasy. I didn't have to file the FATCA form so I can't comment.



> Having lived in the UK most of my life, where I have never had to look at, never mind file a tax return.


Likewise.



> The individual that I had spoken to (that advised me to use a UK based accountant) said the following:
> 
> [..]
> 
> I am curious to see what you think about that???


I think it sounds very much like a dual-qualified tax advisor setting out his stall.


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## Bevdeforges

> Their process, from what I understand, involves me filling out a questionnaire (financial information etc) and then they complete the tax return on the basis of that. While at the same time, asking me the necessary questions to make sure that I have not left anything out.


That's how just about any tax preparation service works - whether located in the US, or anywhere else in the world.

The rest of those "advantages" to a UK based tax preparer are pretty much nonsense. You are always responsible for whatever you file (even if filed by a paid preparer). 
Cheers,
Bev


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## sp84

Huge thank you to both of you! Oversea's filers get an automatic 2 month extension to file from what I understand - but if you owe any taxes, the amount gains interest if not paid by April 15th (what's the point of the extension then I ask myself)!

I found a useful blog about filing from overseas - it recommends some professional companies, but the most interesting part for me were the comments below, with people saying which companies they liked/didn't. It is an independent article so I am pretty sure the posts are genuine.

Bright!Tax were the other company that I had come across on another forum - ever heard of them? I am sure they work the same way as TfE, but what I will say is that they have been incredibly prompt with their replies to emails that I have sent them.

I would really really prefer to do it all on my own - and think that I could if I sat down and focused on it. California being such a difficult state is one of the biggest things holding me back & I think that for this year alone I might just bite the bullet and have them prepared by an expat company.

Also, iota, do you mind if I send you a private message relating to the FBAR. I have submitted them previously but I would be curious to hear your take on my situation/experience with the IRS regarding it.

Thank you again folks, I really appreciate it!


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## iota2014

sp84 said:


> Also, iota, do you mind if I send you a private message relating to the FBAR. I have submitted them previously but I would be curious to hear your take on my situation/experience with the IRS regarding it.


To be honest, I'm not the person you should ask. I only ever filed FBARs to renounce. It was very easy, though tedious, and I never heard from the IRS.


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## Moulard

In theory at least your US taxes shouldn't be that more difficult to prepare than they were when you were living in the US. You should still have copies of at least some those older tax returns to crib off of.

Of course, if you (and our your tax preparer) ignored any assets you left behind during those four years in the US, it may not be a perfect match.

If you did have someone else prepare your taxes previously it can be a bit daunting. But unless your circumstances are extremely complex, you should be perfectly capable of preparing them on your own.

The first year will be more difficult and time consuming as you get to grips with it, but from then on you should be able to copy and paste... except when your circumstances or US rules change.

Key forms you need to consider specific to foreign filing....

Schedule B. You will need to file this even if you have less that $1500 in interest or dividends.

Form 8938 - if the total value of your foreign assets are more than the reporting threshold. (if you are married filing jointly that threshold is $400,000 on the 31 Dec or more than $600,000 at any point in the year. Or $200,000 and $300,000 if filing separately (for example because your wife is not a US person (PR, US Citizen or a Section 6013(g) or (h) election).

Form 2555 and/or its EZ version. This form allows you to exclude the first $101,300 of your income. 

One of the most common reasons that you might want to take advantage of filing extensions is to ensure that you are eligible to exclude income using form 2555, particularly in that first year. To submit the 2555 you must meet a bone fide residence test, or a physical presence test. The presence test is 12 months. but the 12 months only has to be partly in that tax year. 

So lets say for example that you moved back to the UK in August 2016. if you delayed filing until September 2017, when you file you will have been in the UK for 12 continuous months. 
Now you can exclude 100,300 of your foreign earned income. 

How do you get to file that late....You automatically get the 2 month extension by having a foreign address. Plus everyone can file a form to request a further extension that gets you to 15 Oct.

The last bit you need to consider is the FBAR. Technically it is not a Tax form, it has much lower reporting threshold ($10,000) and you have to report on the maximum value during the year.

The other thing it may be worthwhile reading is the UK-US Dual Taxation Treaty to get an understanding of what is protected by treaty and what is not. However bear in mind as a US citizen your protections are likely to be very limited. However the big one is likely to be that the US looks favourably and recognizes UK pension schemes.


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## Moulard

iota2014 said:


> To be honest, I'm not the person you should ask. I only ever filed FBARs to renounce. It was very easy, though tedious, and I never heard from the IRS.


The FBAR goes to the FinCEN not the IRS.. the IRS only does the enforcement and penalties bit on behalf of FinCEN.

The FBAR is easy if you have a "normal human" number of foreign financial assets.

Its basically a simple PDF form that you complete, electronically sign and then upload to FinCEN.

If you don't open and close bank accounts regularly, the first year takes a bit of time to gather all of the account details... really all you need to do is find a current statement and all the core information should be on it. If you have to file Form 8938 then the information required is mostly the same. The only real difference is the dollar amount reported.

Figure out the maximum value of each account during the year. If the total of all accounts is more than $10,000 you have to file the FBAR.

Use the highest balance on a statement (if the account provides periodic statements) convert to USD and add it to the max value field for that account.

Rinse and repeat for each account.

Electronically sign and upload.

What I do is then the next year.. 


remove the electronic signature from the previous filing, 
update the reporting year.
update the max value for each account.
save the pdf with a new file name.
electronically sign and upload.

It takes me about 15 minutes each year to prepare and file the FBAR.

Some people round up just to make life easier.. there is no negative impact to over reporting on the FBAR. But if you are over the FBAR reporting threshold, and under the Form 8938 reporting threshold, you might want to be careful about the rounding up bit...


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## horseshoe846

Moulard said:


> Some people round up just to make life easier.. there is no negative impact to over reporting on the FBAR. But if you are over the FBAR reporting threshold, and under the Form 8938 reporting threshold, you might want to be careful about the rounding up bit...


In fact - I round up quite a bit - why not ? 

I'm not clear of the relationship you draw between (the dollar amount reported) on a fbar filing and an 8938 ?. Why not 'over-report' on the 8938 as well ?


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## iota2014

Moulard said:


> .. the IRS ... does the enforcement and penalties bit on behalf of FinCEN.


Correct. And I never heard from them, whereas the OP apparently did.


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## Moulard

horseshoe846 said:


> In fact - I round up quite a bit - why not ?
> 
> I'm not clear of the relationship you draw between (the dollar amount reported) on a fbar filing and an 8938 ?. Why not 'over-report' on the 8938 as well ?



All I was trying to suggest is that you might not want to round up to a point where you actually have to file the 8938 is all. I

Between the FBAR and 8938 reporting thresholds all you have to do is file Schedule B.

Of course there is no harm in filing a 8938 even if you don't have to.


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## Bevdeforges

Moulard said:


> Of course there is no harm in filing a 8938 even if you don't have to.


You don't have to file a 8938 at all if you don't have a tax filing requirement. (I.e. if your income is below your filing threshold). And in any event, best not to file something like that if you aren't required to. If you do file it, it can then be "used against you" as they say in the Miranda warning. <g>
Cheers,
Bev


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## Moulard

Indeed. 

However given that the discussion has been about filing taxes, I have assume that the OP has already decided that they do indeed need to file.

I might argue that sometimes it is better to file even when it isn't technically required.

Case in point, when my partner was going through green card interview in Australia, the person in front in the queue got knocked back because they did not have the requisite number of tax returns to show. She was a stay-at-home mother and the NRA spouse was the breadwinner. The consulate basically turned her away, said file those unnecessary returns and then come back and we can continue the conversation.


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## Bevdeforges

As with many things in Life, it all depends. If you are potentially going to sponsor a spouse for a visa/Green Card, then sure, you should probably file, even if you don't have to based on earnings. But my father received a letter from the IRS telling him that, unless his situation changed, he should NOT file any more returns. (This was after he retired and was living off his IRA account.) I note, too, that he was in the US - I don't think they send those letters out to folks living overseas.
Cheers,
Bev


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## sp84

Thanks for all the information folks - and I apologise in advance for the length of this post ... 

My 4 years living in the USA consisted of my (USA) wife and I having a local accountant prepare our tax returns. Our income was relatively modest and so the returns were straight forward from what I understand - with only a few deductions such as student loan interest etc to take into consideration. 

We never owned any assets in the USA (no house, bonds, shares etc) - so the first year we filed we were owed some money back ... the following years we did owe a small amount. Mainly due to how our employers recorded us for our W-2's and also we had to repay some of the assistance that we received through the Affordable Care Act. 

During my 3rd year living there - that is when I found out about the FBAR. No accountant had ever asked me did I hold a bank account back home in the UK. So this started a long and very stressful journey. I will try to summarise this as best/short as possible below:

I have a UK bank account that had over the required $10k needed to qualify for FBAR filing (so obviously since getting my green card, I had not filed this as is required). I looked into the accounts and one is my main savings account (current account with 0% interest, so I never earned anything from that while living in the USA), but I had another account, which throughout the few years living in the USA. earned a grand total of 12 cents per year in interest. 

So last April, in order to come into compliance I called the IRS Helpline for the FBAR Streamlined Program. I wanted to make sure that I used the correct IRS program to "come clean". I explained that one of my accounts had earned a very very small amount of interest. The lady told me that because of that 12 cents - I *MUST* use the more complicated Streamlined Program, instead of the more straight forward "Delinquent FBAR Submission Procedures". Which require you to simply file and outstanding FBAR's as long as you do not owe any tax on them.

The more complicated Streamlined Program would require me to file 3 years of amended tax returns (showing the unreported income of 12 cents) and file the last 6 years of FBAR's (even though I have only been in the USA for 3 years). Also, I would be charged a 5% penalty of the highest balance in my accounts (all because of 12 cents per year!) The lady then said she would call me back the next day, in order to clarify a few things.......

The IRS lady called me back the next day and started explaining the Streamlined procedures to me again (including the penalty) - first she said about sending in FBAR's going back 6 years, to which I said that I have only had a filing obligation for 3 ... Then she mentioned amending my last 3 years of returns - I told her that my accountant said that anything below 50 cents will not alter my overall income amount, as the tax return forms round all figures down. Thus, 51 cents and up would have changed my income. So she said she would speak to a colleague and call me back ...

When she called again - she basically said not to worry about the 12 cents - that I shouldn't use streamlined program and should just use the easier "delinquent FBAR procedures" - file my late FBAR's, with no amended tax returns and that will be that.

So I questioned her and asked - what if I am audited in a few years and someone points out that 12 cents that I (in theory) should have reported - and that I am in trouble because I should have use the streamlined program. (We all know the penalties associated with FBAR's I am sure)! She responded:

1) We will not audit you over 12 cents - we do not have the time or money to do that
2)Nothing about you would flag up that you need to be audited
3) As long as I have a paper trail showing where I came up with the 12 cents, I would be OK
4) She would call me back on Tuesday with her full name and IRS badge number - so that again if I were challenged I could quote, per my conversation with her (she is an auditor for the Steamlined Program) - that she advised me not to use the Streamlined program & that I should use the easier Delinquent Program.
5) I would not be going to jail or losing my home (if I had one)!

So the last year or two has been a pretty stressful time - in terms of hearing horror stories relating to the FBAR & even around living overseas and having to file. That is why for this particular year, seeing as I spend half of 2016 in the USA and the other half in the UK - I have been leaning towards one of those professional online companies that specialise in expat taxes.

Phew that was a lot! Sorry for it being so long, but because everyone has been so responsive I wanted to pretty much disclose my entire situation to see what people think.

Thanks!


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## Moulard

A long post deserves an ever longer response

Others may have a slightly different view and will no doubt chip in…

First, I would file the delinquent FBARs select "Did not know I had to file" or another relevant reason from the dropdown list. Gather together your bank statements. If they are monthly or quarterly find the month that has the highest balance and convert to US Dollars for each account.

You say that you moved to the US 4 years ago… if that is the case you should not have to report more than 4 maybe 5 FBARs. Basically report for each year that you were either a resident alien or US citizen up to the 6 years.

You can hold off filing the 2016 one if you like… it isn’t due until 15 April, but you get an automatic extension to 15 October now. But if you are doing FBARs you might as well do them all in one hit.

Next consider what you need to do in terms of amended returns. 

I would suggest starting with your 2013 return, because of the rules about how and when the IRS can decide to audit are that they have 3 years unless you have been willfully fraudulent. That is from when the original return was file, not from when the amended return was filed. 

The rules are a bit convoluted, but basically you can amend up to three years from the date that your returns were filed in light of the fact that you are likely only meeting additional reporting requirements . So that means you can amend your 2013 return up to 15 April this year, assuming you filed on time. If you filed late, you have until that date.

Sounds like you were in the US all of 2013-2015. Amending these returns should be simple. Dig out the printed copy of your original returns, go to the IRS website and download the 1040X and the prior year version of schedule B for each year.

If you did not file schedule B previously complete Part III. 
If you did file schedule B, copy the information from the original return and complete Part III.

I am going to guess that you earned less than $1500 in Interest globally and therefore did not file Schedule B.

Amend the Adjusted Gross Income line of the 1040X to reflect the rounded amount of interest in USD. Sounds like it might be an additional $1, at worst depending on currency conversion rates. But if it has been 1 pence of interest a month, you aren’t going to get to $0.50 at any point.

Next consider the maximum value of your foreign assets. Depending on the maximum value you may also need to file Form 8843. Read the instructions and find the reporting threshold relevant to you.

If you are above the 8843 threshold you need to file it, using the same information as you gathered for the FBAR (its why I suggest doing it first), except you report the balance is USD on 31 December.

Work out the additional tax due IF you added $1 or more. Because of the way the IRS calculates taxes on incomes of less than 100,000 you will have to be very unlucky to owe more tax.

Assuming the US part of those returns are in order, that is likely to be the extent of it based on what you have posted. Post them the 1040X, Schedule B, any the 8843 if required.
Done and Dusted. Your past returns should be in order. Then take a deep breath, and you can start thinking about the 2016 ones. You have to 15 June. Or if you are feeling traumatized by it all File Form 4868 and you automatically get an extension to 15 October. 

I would do that, to ensure that you can file form 2555 for 2016.


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## Bevdeforges

And, as they used to say - now for a responsible alternative opinion:

The FATCA requirements for the FBAR only really kicked into high gear for 2014 or 2015 depending on what country you're living in. That's when the bank reporting for FATCA first started. The bank reporting requirements are rather different from the individual reporting requirements.

If all this is only over a savings account paying a whopping $1 a year in interest or less, I'd just let it go. They really and truly are not going to come after you for that - if they ever managed to discover it (bank reporting or no bank reporting).

Your chances of being audited while resident overseas are very, very slim unless you're in the upper upper income brackets and have very complicated investments that are likely to arouse suspicions of tax fraud. (In which case, paying a tax accountant is probably a deductible expense anyhow and well worth the money.)

If you're filing an "informational" return (like most of us living overseas) - namely reporting your income but paying no taxes on it - then you should be able to make a "good faith" effort using commercial tax preparation software and be done with it. The first time through is the toughest - after that, you just follow the pattern.
Cheers,
Bev


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## Moulard

Actually I think Bev and I are saying the same thing.. just in different ways...

On the FBAR...

SP84 says... IRS tells me I must file 6 years of delinquent FBARS...
Moulard says... wait... from what you say.. you wasn't a US person for 6 years... I call ********..
Bev says.. the same thing... but is far more polite than I am.

On amended returns...

Bev says... ignore it... its a trivial amount.
Moulard says... yep. its a trivial amount. But maybe to make you feel better, submit the forms..

All it might mean is that you can sleep quietly tonight.

I have been almost where SP has been. I understand the irrational fear that is created.

Sometimes over reporting, and over filing, gives you a sense of control. And when you feel like you have been caught by surprise taking control of the situation makes you feel in control.

Sometimes that is a good thing. With the past behind you, you can take a sane and rational approach moving forward.

Sometimes dotting the i and crossing the t is important, if only to provide one with the sense of security that you have done as much as possible to resolve the irrational thoughts that men in black suits will come and bankrupt you, extradite you etc....

That gut reaction, however illogical is hard to fight.

SP84 has 6 months plus to figure out what do do with 2016. Sometimes just having a plan is enough to move on with and gain the courage to proceed.


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## Moulard

whoops the larrikin in me has come out.. It appears I should not have referred to bovine effluence.

But might point still stands.

Sometimes just to sleep soundly at night, a 1040X with an additional information only type attachment that has no change to taxable income is worthwhile.

For what its worth... in the 30 plus years I have been filing (I must thank my parents for letting me know that I had a filing obligation when I brought home my very first pay-cheque.) I have probably never filed a return that would pass the scrutiny of an audit. 

But sometimes it takes a bit of time and distance to come to the realisation it probably doesn't matter.

Ultimately make sure you are happy with the last three years of returns so that you sleep well at night. Because unless the numbers have 6, 7 or more figures the IRS is unlikely to care.


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## iota2014

Worrying unnecessarily about IRS agents in black suits turning up to extradite you is not a good way to try to gain a sense of control.

For a USC residing outside the US, arealistic understanding of local law, IRS priorities, and IRS constraints is more helpful than succumbing to paranoia. IMO.


----------



## Moulard

iota2014 said:


> Worrying unnecessarily about IRS agents in black suits turning up to extradite you is not a good way to try to gain a sense of control.
> .


No. But sometimes being able to do something, even it if is only to draw a line in the sand, is. 

If all it will take for SP to become compliant (or at least as compliant any human can be with thousands of pages of contradictory tax code) is to submit a schedule B with three checks on it, then why not do it. If only to sleep soundly at night.

At worst, nothing happens. At best, SP is better armed to deal with future years.


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## sp84

Thank you everyone, 

Apologies but what I should have pointed out was the following:

For each year that I lived in the US, my wife and I filed our tax returns on time and paid any tax that was owed. 

Then this time last year, I learnt of my requirement to file the FBAR (and also learnt that I should have filed them along with my previous tax returns).

The IRS has several programs available for people that have to file delinquent/overdue FBAR's. Obviously you have to use whichever program is best suited to your situation. There were 2 main programs available to me:

(1) The Streamlined filing procedure - this is the program that requires 6 years of amended tax returns (declaring interest that you earned & paying any tax on that interest), plus paying a 10% fine based on the value of the accounts that you failed to declare.

(2) The Delinquent FBAR submission procedures (https://www.irs.gov/individuals/international-taxpayers/delinquent-fbar-submission-procedures) - this program requires no amended returns and for the person to simply file their overdue FBAR's to come into compliance. You are only allowed to use this program, if you do not meet the requirements for #1.

As I had earned a massive 12 cents per year on my small savings account (which I hadn't declared on previous tax returns) - I assumed that I 100% had to use option #1, the Streamlined Program. so I called the Steamlined Helpline in order to get clarification and also information about what steps I needed to take in order to "come clean"

Then, after my phone conversation (over 2 days) with the IRS Streamlined Helpline (as detailed in my previous post) - the agent eventually said, don't worry about the 12 cents & paying the 10% penalty, simply use option #2 ... file the FBAR's I was required to file, no need for amended returns etc and that would be that - so that is what I did.

I filed 2 Delinquent FBAR's, selecting "I did not know I had to file" and then also submitted last years FBAR to that (which I was filing on time), so 3 in total ... However, as mentioned I did not file any amended returns - all based on my phone conversation with the agent/her recommendations.

I have an archived email to my accountant saved as evidence - in the event that I am ever audited and they try to fine for me not using option #1.

The bank account that earned the 12 cents has since been emptied - so I only have 1 account now to report and it does not earn any interest. 

If that makes any sense to you all!

So do you still think I need to file amended returns etc, or just leave it at that? :fingerscrossed:


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## Moulard

It appears that you have answered your own question. 

If the nice friendly people at the IRS said to file the delinquent FBARs but not to worry about filing amended returns... then take that advice. I would print out a copy of that email and staple it to the hard copy of your return... just in case.. 

If they said, it to you and you have no evidence. minute the conversation, sign and date it and file it away. again just in case.


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## sp84

Moulard said:


> It appears that you have answered your own question.
> 
> If the nice friendly people at the IRS said to file the delinquent FBARs but not to worry about filing amended returns... then take that advice. I would print out a copy of that email and staple it to the hard copy of your return... just in case..
> 
> If they said, it to you and you have no evidence. minute the conversation, sign and date it and file it away. again just in case.


Thanks Moulard - just curious what you mean by "If they said, it to you and you have no evidence. minute the conversation, sign and date it and file it away. again just in case."

I have the email that I sent to my accountant (detailing what the IRS told me) - saved and archived in my emails. It has the time stamp of April 15th 2016 on it. You think I should also just print it out and have a hard copy on hand just in case? (at least I assume that is what you are saying?)


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## Moulard

With anything electronic, one should have backup and redundancy. I see paper as the ultimate backup. Actually I think I see it the other way round. The electronic copy is the backup.

Ask yourself two questions ... 

Will you always have access to that email account?
Will you always have access to that accountant?

The answer is almost definitely going to be yes in your case. 

My habits predate cheap and reliable hard-drives and cloud hosted email.

The real reason I keep printed copies of key documents and minute important conversations has nothing to do with taxation. It has to do with legal proceedings that I was involved in. 

The plaintiff indicated that they had no record of ever having received a letter. I had copies not only of the letter I sent, but also a reply from them that referenced information that would only have been known if they had actually received the original correspondence from me. 

Needless to say, a Manila folder that had been sitting ignored at the bottom of a filing cabinet for years saved me a significant amount of grief.


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## sp84

Moulard said:


> With anything electronic, one should have backup and redundancy. I see paper as the ultimate backup. Actually I think I see it the other way round. The electronic copy is the backup.
> 
> Ask yourself two questions ...
> 
> Will you always have access to that email account?
> Will you always have access to that accountant?
> 
> The answer is almost definitely going to be yes in your case.
> 
> My habits predate cheap and reliable hard-drives and cloud hosted email.
> 
> The real reason I keep printed copies of key documents and minute important conversations has nothing to do with taxation. It has to do with legal proceedings that I was involved in.
> 
> The plaintiff indicated that they had no record of ever having received a letter. I had copies not only of the letter I sent, but also a reply from them that referenced information that would only have been known if they had actually received the original correspondence from me.
> 
> Needless to say, a Manila folder that had been sitting ignored at the bottom of a filing cabinet for years saved me a significant amount of grief.


Very valid point - I do prefer paper copies myself so as a precaution I will print it out.

As you folks are so responsive and seem knowledgeable on the subject - can I ask another question about the FBAR?

So when I filed my 3 FBAR's last year (2 overdue and 1 on time) - I provided the information in relation to all of my savings accounts. 

A few months later, while using the app on my phone for online banking - I remembered that I have a credit card with the same bank (with a very modest maximum limit), which I did not include on the FBAR.

I have since spoken to 2 other people about this. 1 on another immigration forum and 1 an American living here in Northern Ireland. Both have been adamant that the FBAR is related to reporting foreign assets - so therefore a credit does not need to be reported (unless you overpay it and the balance becomes positive). Both of these individuals have also got credit cards and neither of them report them on their FBAR's.

I was just curious to get some input from you all and see what you think?


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## Moulard

Credit cards accounts do not need to be reported. 

They aren't generally as asset, more of a liability really. 

I have seen that documented somewhere. Just not sure where.

I think it is in the line instructions for the FBAR about what is and is not a financial account.


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## Bevdeforges

And to expand just a bit. FBARs are for foreign financial accounts only - bank accounts, investment accounts.

Financial assets are reported on the 8938 if you meet the threshold requirements.

But foreign credit cards don't show up on either report. Credit cards basically have no relevance to your income taxes (at least not in the US).
Cheers,
Bev


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## iota2014

A certain dual-US-UK-qualified tax advisor (yes, the same one) used to advocate counting credit card accounts, public transport card accounts, bus passes, society membership accounts and more or less any old piece of plastic with a number on it. 

A moderately-redacted IRS ruling letter at https://www.irs.gov/pub/irs-wd/0603026.pdf has some comments on when a credit card account might possibly require an FBAR (basically when it's being treated as a deposit account). (Also some comments on willfulness - maybe more pertinent to non-hifi-expats trying to comply without being scalped.)


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## sp84

iota2014 said:


> A certain dual-US-UK-qualified tax advisor (yes, the same one) used to advocate counting credit card accounts, public transport card accounts, bus passes, society membership accounts and more or less any old piece of plastic with a number on it.
> 
> A moderately-redacted IRS ruling letter at https://www.irs.gov/pub/irs-wd/0603026.pdf has some comments on when a credit card account might possibly require an FBAR (basically when it's being treated as a deposit account). (Also some comments on willfulness - maybe more pertinent to non-hifi-expats trying to comply without being scalped.)


Thanks everyone - sorry for the late reply (new born baby and I am a teacher - so resource planning for next week took up most of the last few days!)

I am just curious to understand what you mean by when a Credit Card is being treated as a deposit account? - as in there in money going into the account e.g. say from my employer after a weeks work? or am I way off base with that?

In addition, as you already know from the start of this thread, I have been emailing some expat tax preparation companies (some based in the USA and some based here in the UK).

A UK based company replied (with a pricing quote of £1250 plus VAT I might add), but with this little bit that I thought was interesting (And I hope some of you could maybe shed some light on). The company said the following:

_The fee will include, Form 1040 (income tax return) along with consideration of if you would qualify for the foreign earned income exclusions and foreign housing exclusions as standard. If you are employed and paying UK tax via PAYE, it tends to be more beneficial not to claim the foreign earned income exclusions due to the way the calculations are run, but we would check this as part of your filings. I expect you will qualify for a part year exemption from the ACA, but not for the period you were physically present as a resident of the USA._

The part underlined is the bit I am most curious about! Obviously along the way throughout this post - some of you have suggested filing an extension - so that I will pass the 330 days and be able to make use of the FEIE.

Just curious if any of you understand why the lady is saying it is more beneficial not to claim it?

Cheers & hope your weekends are going well!


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## iota2014

> I am just curious to understand what you mean by when a Credit Card is being treated as a deposit account? - as in there in money going into the account e.g. say from my employer after a weeks work? or am I way off base with that?


Card being run with a credit balance. Cards sometimes go temporarily into credit by accident, for instance when you return a purchase after you've paid the card bill, but apparently it's also possible with some cards to keep the card substantially in credit, which of course could be seen as hiding cash for tax evasion or ML purposes.

I seriously doubt if you could arrange for your salary to be paid to a credit card account, here in the UK.

For normal credit cards used normally, no need for an FBAR.


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## Moulard

Another example of non-standard accounts that can be treated as such are mortgages. 

Normally a mortgage would not be a reportable account, but as an example, some have a redraw facility. If you make more than the minimum payments that effectively leaves them with a balance that can be drawn upon in the event of an emergency. 

Thus a loan becomes an account.


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## Bevdeforges

> The fee will include, Form 1040 (income tax return) along with consideration of if you would qualify for the foreign earned income exclusions and foreign housing exclusions as standard. If you are employed and paying UK tax via PAYE, it tends to be more beneficial not to claim the foreign earned income exclusions due to the way the calculations are run, but we would check this as part of your filings. I expect you will qualify for a part year exemption from the ACA, but not for the period you were physically present as a resident of the USA.


I would dispute the underlined part - but in any event, it looks to me to be a way to try and justify their rather outrageously high fees. The FEIE is very often the quickest and easiest way to discharge your US filing responsibility without having to make any payments. And frankly, if your main source of income is salary, it's easy enough to do it yourself once you take the time to figure out the forms. 

If you don't take the FEIE, there is the possibility of doing some "creative accounting" - for example, contributing to a 401K or IRA back in the US, or in some cases, claiming a refundable credit. Unfortunately, once you choose not to take the FEIE, it can be difficult to go back to it should your situation shift or you change your mind. (You need permission from the IRS and there is a certain time period during which you cannot shift back.) 

Many tax preparers assume that their clients want the biggest possible refund, including any refundable credits that may be available, whereas for many folks, the goal is simply to discharge their obligation without having to pay tax (or to pay the minimum amount possible). There are also circumstances, such as when a US citizen is married to a non-resident alien who has no US tax filing obligation, where taking the tax credit is downright disadvantageous. The FTC is not a dollar for dollar tax credit - what you paid in your country of residence vs. your US tax liability. It's more a proportioned allocation of what you paid and what you owe. If the FEIE eliminates your tax obligation quickly and easily, it can be well worth it to just file that way and be done with it.
Cheers,
Bev


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## iota2014

Moulard said:


> Another example of non-standard accounts that can be treated as such are mortgages.
> 
> Normally a mortgage would not be a reportable account, but as an example, some have a redraw facility. If you make more than the minimum payments that effectively leaves them with a balance that can be drawn upon in the event of an emergency.
> 
> Thus a loan becomes an account.


Not something a USC expat needs to worry about or file an FBAR for though, assuming they're not in fact using credit cards and offset mortgages for tax evasion or money laundering or financing terrorists.

The guidance on what requires FBARs is at https://www.irs.gov/businesses/comparison-of-form-8938-and-fbar-requirements. No need to worry about credit cards and mortgages, since they're not listed there.


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## Moulard

Although to be fair they could both be considered an account given the analysis in that PLR you posted.

I do have to say, I like the idea of reporting my bus pass. It does have a balance, and I can use it to pay for certain services. I can even ask to withdraw the balance... .. Even my club membership has a yearly advance that I have to pay them, so that no filthy lucre has to be touched. 

If I try real hard... I might even be able to get above that 25 accounts threshold for the FBAR...


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## iota2014

The 25 accounts anomaly was going to be abolished. Proposed regulations were published some time ago. Perhaps they never got round to the final stage.


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## Moulard

Its been a little while since I looked, but I believe that above 25 accounts you don't have to complete that form. At that point you are treated the same as a paid preparer or an institution that can do bulk uploads. You still file, just a different way.


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## iota2014

Yes. Regulations were proposed to abolish it.


> The proposed rule would expand and clarify the exemptions for certain U.S. persons with signature or other authority over foreign financial accounts. In addition, the proposed rule would remove the special rules permitting limited account information to be reported when a U.S. person has financial interest in or signature authority over 25 or more foreign financial accounts.


https://www.fincen.gov/sites/default/files/shared/FBAR_NPRM030116.pdf


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## sp84

Thanks so much everyone! I'm enjoying reading the different responses and never thought my initial post would garner so much interest! 

Two other things have come to mind which I thought I would throw out there (I know I am probably over analysing haha)...

(1) I know that several of you have advocated that I file for an extension, thus taking me over the 330 days needed to make use of the FEIE scheme. My question is this ... I moved home to the UK on 14th June 2016. However, in order to complete my US citizenship application, I had to fly back to the USA for 10 days in November 2016. Finally, as my wife and I just had the new baby - her family in the US are expecting us to spend some time in the US during the summer. Ssssooooo - does my time living outside the US being on June 14th? Or have I reset my clock/messed things up, by flying back there in November? Does this mean that I can/can't use FEIE?

(2) As mentioned in a previous post I am a teacher here in the UK (a normal public High School here in Belfast) and my wages are paid by the Department of Education Northern Ireland (DENI). A bog standard by product of being in a public job, is that from my wages every month - the government takes out a portion for my pension contribution. This is a government based pension, where if my understanding is correct - it holds no true value as of right now ... and I am effectively paying into a "pot" along with all the other teachers here in Northern Ireland. I spoke to another US Citizen based here in Northern Ireland. He has lived here for 20 years and works for the Civil Service. His job is also in the public sector (like myself) - so he automatically makes contributions towards a similar pension scheme. He also has a private pension plan through his employer. On his FBAR/tax returns he does not (and does not plan on) disclosing his government based pension. However, he does disclose his private/employer pension plan ... After discussing it with him (and a user on another forum) I have not included my government based pension with my previously filed FBAR's/tax returns - as it effectively has no value (unlike when you do not know the value and are asked to put $0) ...

Just curious if that sounds about right with everyone?


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## Bevdeforges

The government based pension is NOT an FBAR item. Your friend's private pension fund (i.e. where he contributes a fixed amount and has control over the balance in his account - how it is invested, and ultimately how and when he takes it out) is a pension fund that belongs to him and therefore is reported as a "financial account."

The physical presence test requires you to have been outside the US for 330 days during a period of 12 consecutive months. Therefore, for the period from 14th June 2016 to 13 June 2017 you can return to the US for up to 35 days in order to fulfill the requirement. If you were only 10 days back there, then no problem. If you're planning on returning for some time during the summer, I'd just plan on not going back until the month of June - so that during your June to June timeframe, you would not have spent 35 days back in the US. But it does mean you need to wait until after June 14th 2017 to file your 2016 return.
Cheers,
Bev


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## Moulard

Bevdeforges said:


> But it does mean you need to wait until after June 14th 2017 to file your 2016 return.


You automatically get an extension to the 15 June because of your overseas filing address. However in this case, you will want to get an extension to 15 October by filing Form 4868.

I would complete my return, so that it is ready to file now, then submit form 4868. 
Then at any time after 15 June but before 15 Oct, dust it off and file the return.


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## sp84

Thank you so so so much everyone. You have no idea how much I appreciate it - and actually being able to speak to individuals that know their stuff, has helped alleviate a lot of my underlying fears (e.g credit cards, teachers pension etc).

I know you will all probably shake your heads in shame lol but what I think I will do this year is file the extension as mentioned and then have one of the expat companies such as Bright!Tax prepare my taxes (the Californian tax return is a massive factor for me in this decision).

Then I will obviously prepare and file my own FBAR.

Now I know this year, the filing date for the FBAR has been changed to coincide with April 15th (the regular date for filing taxes in the USA) - but am I right in saying that you also have until October to file this too? I remember reading a statement about this somewhere, but the wording was extremely vague.


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## Moulard

That is correct, you have until 15 Oct to file the FBAR for 2016.

So.. FBAR is now due 15 April with an automatic extension to 15 October, aligning with tax return due date of 15 April with automatic extensions possible for overseas filers to 15 Oct.

This change was made late last year, so this is the first year with the new dates.


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## sp84

Moulard said:


> That is correct, you have until 15 Oct to file the FBAR for 2016.
> 
> So.. FBAR is now due 15 April with an automatic extension to 15 October, aligning with tax return due date of 15 April with automatic extensions possible for overseas filers to 15 Oct.
> 
> This change was made late last year, so this is the first year with the new dates.


Sorry for the late reply again Moulard! Mental few days with the wife (post birth) - involving an ambulance and a few days back in hospital. Thankfully all is good now!

you said - to align with automatic extensions possible for overseas filers (so that would be Oct 15th if an extension is granted) - for both the tax return and FBAR.

Not that I doubt you, but I could have sworn absolutely everything I read last year regarding the FBAR - was all about it being due on April 15th - with no possibility of an extension...considering it is not actually managed/policed by the IRS.

I know you said it changed late last year - but I just wanted to verify that?

Also - if I file the form for an extension, will that give me an extension for both my federal tax return and my state (California) tax return?

Cheers!


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## Bevdeforges

BSA E-Filing System - No Registration Filing FBAR

First section under General Instructions:


> FinCEN will grant filers failing to meet the FBAR annual due date of April 15 an automatic extension to October 15 each year. *Accordingly, specific requests for this extension are not required*


Extension Of Time To File for Individuals
explains the extension for California state taxes.
Cheers,
Bev


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## sp84

Bevdeforges said:


> BSA E-Filing System - No Registration Filing FBAR
> 
> First section under General Instructions:
> 
> 
> Extension Of Time To File for Individuals
> explains the extension for California state taxes.
> Cheers,
> Bev


Thank you Bev!

The thing that has confused me all along about the extension is that - yes you get an extension to file ... but not an extension to pay. So effectively, if you owe anything (both federally and/or state) - you have to pay it by April 15th (even if you have until Oct 15th to file) or else you are forced to pay interest and possibly even a penalty . 

This is from the California state tax website that you sent me: _An extension of time to file is not an extension of time to pay. You do not have to pay any tax due with Form 4868. However, if you do not pay the amount due by the regular due date, you will owe interest on the unpaid amount. You may also be charged a penalty for paying the tax late unless you have reasonable cause for not paying your tax when due. You are considered to have reasonable cause for the period covered by the automatic extension if at least 90% of the tax shown on your return is paid before the regular due date of your return through withholding, estimated tax payments, or with Form 4868 and any balance due on the return is paid with the return._

Surely that defeats the point of the word "extension"? The wording at the end of that quote is quite confusing (the part I have underlined.


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## Moulard

sp84 said:


> The thing that has confused me all along about the extension is that - yes you get an extension to file ... but not an extension to pay. So effectively, if you owe anything (both federally and/or state) - you have to pay it by April 15th (even if you have until Oct 15th to file) or else you are forced to pay interest and possibly even a penalty .



The purpose of the 2 month automatic extension (to 15 June) for IRS filings is purely a consideration of the fact that it takes longer in the post than an extended return.

Someone in Sacramento can drop it in the post on the 13th of April and still file on time. Someone in Niamey could not.


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## Bevdeforges

It has pretty much always been this way - an extension to FILE is not an extension to PAY. Even if you meet the April 15th filing deadline, you are expected to have covered at least 90% of your tax obligation either through withholding or quarterly Estimated Payments. (There is also a safe harbour provision if you have remitted at least 100% of what you owed for the prior year.)

But they really do expect you to settle up by the April 15th filing deadline, extensions or no.
Cheers,
Bev


----------



## sp84

Bevdeforges said:


> It has pretty much always been this way - an extension to FILE is not an extension to PAY. Even if you meet the April 15th filing deadline, you are expected to have covered at least 90% of your tax obligation either through withholding or quarterly Estimated Payments. (There is also a safe harbour provision if you have remitted at least 100% of what you owed for the prior year.)
> 
> But they really do expect you to settle up by the April 15th filing deadline, extensions or no.
> Cheers,
> Bev


Aaahh OK - well I better get on the ball then this next week or so! So a few yes or no questions just to verify if that is OK?

(1) As I am filing from overseas, my automatic extension to FILE is June 15th, correct?

(2) As I am filing from overseas - is my date to PAY April 15th or June 15th?

(2) Paid by the 15th April means post stamped/dated April 14th is still considered on time? Even if filing/paying by mail from overseas?

(3) Can you both FILE online and PAY online?

(4) I am sure my question for this will be answered when I look at the form to extend to Oct 15th - but my wife and I normally file a joint tax return - will one form (to extend), cover both of us, or will I need to fill in two forms (one for each of us)?

Cheers! Sorry about bombarding with lots of questions - it's the teacher in me and I am trying to learn/understand the process.


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## Bevdeforges

sp84 said:


> Aaahh OK - well I better get on the ball then this next week or so! So a few yes or no questions just to verify if that is OK?
> 
> (1) As I am filing from overseas, my automatic extension to FILE is June 15th, correct?
> 
> (2) As I am filing from overseas - is my date to PAY April 15th or June 15th?
> 
> (2) Paid by the 15th April means post stamped/dated April 14th is still considered on time? Even if filing/paying by mail from overseas?
> 
> (3) Can you both FILE online and PAY online?
> 
> (4) I am sure my question for this will be answered when I look at the form to extend to Oct 15th - but my wife and I normally file a joint tax return - will one form (to extend), cover both of us, or will I need to fill in two forms (one for each of us)?
> 
> Cheers! Sorry about bombarding with lots of questions - it's the teacher in me and I am trying to learn/understand the process.


(1) yes
(2) Date to pay is still April 15th - theoretically that is the date for sending in your fourth Quarterly Estimated Payment. Total of your 4 estimated payments must equal either 90% of what you ultimately owe or 100% of what you owed last year.
(3) theoretically yes, however the methods of payment online from overseas are somewhat expensive: https://www.irs.gov/payments
(4) If you file jointly, then you only need to file one form to extend.
Cheers,
Bev


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## Moulard

Early on in the thread I suggested that you basically get your taxes pretty much all ready to file before the 15 April. One of the reasons I did that was so that you would be in a position to determine whether or not you actually owe the US anything.

If you will not owe anything (or at least , then you can safely sit on it until after you are eligible for the 2555 under the physical presence test. Remember to set yourself a reminder. Real easy to forget to file... particularly when it is all done bar the signing and posting.

If you do believe you owe them something, then you can pay what you believe you will owe before 15 April, and update the return as required..and then sit on it as above.


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## sp84

Bevdeforges said:


> (1) yes
> (2) Date to pay is still April 15th - theoretically that is the date for sending in your fourth Quarterly Estimated Payment. Total of your 4 estimated payments must equal either 90% of what you ultimately owe or 100% of what you owed last year.
> (3) theoretically yes, however the methods of payment online from overseas are somewhat expensive: https://www.irs.gov/payments
> (4) If you file jointly, then you only need to file one form to extend.
> Cheers,
> Bev


Thank you Bev, 

(1) So if we were to pay what we owe (from overseas) via that website - we would select "Pay with your debit/credit card"? is that correct?

(2) Not sure if this makes a difference (I am guessing that it might though) - but my wife and I still have a US bank account (she has to have one to repay her student loan) ... we planned on paying anything we owed from that account anyway. I am hoping that is more straightforward & cheaper, than paying online from overseas? As effectively we would be paying domestically?

(3) Also, in order to pay via the mail - I thought maybe that her family could always pay via check for us (from their own accounts) and we could reimburse them/transfer money to their account?

Do either option 2 or 3 sound do-able/easier/cheaper than what you would class as "paying online from overseas"?


----------



## Moulard

I have maintained a US bank account, with a checking account purely for situations like this. 

If you have a US bank account you should be able to do an EFT from that account, no different than if you were located in the US. 

I think I would go that route, over writing a check and posting it. (you at least know it has been received)

Never had to pay US taxes since leaving the US, but I have found that the validation steps with some credit cards have real problems dealing with US bank based credit cards with foreign addresses... or foreign credit cards.

So in short, if you have a sufficient balance in your US account, I would pay with your US debit card.


----------



## sp84

Moulard said:


> I have maintained a US bank account, with a checking account purely for situations like this.
> 
> If you have a US bank account you should be able to do an EFT from that account, no different than if you were located in the US.
> 
> I think I would go that route, over writing a check and posting it. (you at least know it has been received)
> 
> Never had to pay US taxes since leaving the US, but I have found that the validation steps with some credit cards have real problems dealing with US bank based credit cards with foreign addresses... or foreign credit cards.
> 
> So in short, if you have a sufficient balance in your US account, I would pay with your US debit card.



Perfect Moulard, thank you! I might have a bit of a problem with the section I have underlined - because California is such a difficult state to leave - we changed our mailing address to here in the UK. If it does become an issue with the validation steps - couldn't we just have a family member of my wife's pay it electronically via their account and we then do an EFT to reimburse them?


Also, sorry I didn't get a notification for the previous post that you had put up. You said: _Early on in the thread I suggested that you basically get your taxes pretty much all ready to file before the 15 April. One of the reasons I did that was so that you would be in a position to determine whether or not you actually owe the US anything.

If you will not owe anything (or at least , then you can safely sit on it until after you are eligible for the 2555 under the physical presence test. Remember to set yourself a reminder. Real easy to forget to file... particularly when it is all done bar the signing and posting.

If you do believe you owe them something, then you can pay what you believe you will owe before 15 April, and update the return as required..and then sit on it as above._

My wife and I will definitely owe some tax - because of how our previous employers classed us on their books. If I remember right - it is normally around 10% of what we made for the year.

So I am just confused by what you mean by "update as required" ... if we have the tax return completed for April 15th, discover what we owe and then pay it - shouldn't it then just be a matter of just sitting on the tax return (so waiting to file until the 330 days are up), then filing.

What would we need to update? As the tax return is for earnings Jan 2016 - Dec 2016?

Sorry that reply is a little messy and for the duplication here below - I am not sure if it is possible to quote from 2 posts - so to summarise, what I am asking is:

(1) If it does become an issue with the validation steps - couldn't we just have a family member of my wife's pay it electronically via their account and we then do an EFT to reimburse them?

(2) I am just confused by what you mean by "update as required" ... if we have the tax return completed for April 15th, discover what we owe and then pay it - shouldn't it then just be a matter of just sitting on the tax return (so waiting to file until the 330 days are up), then filing.

What would we need to update? As the tax return is for earnings Jan 2016 - Dec 2016?

Cheers!


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## Moulard

...Update as required...

Sorry.. what I meant was update the section on the 1040 that indicates taxes paid to reflect any amount you pay between now and the date that you submit taxes. Assuming you want to avoid any potential penalty or interest for late payment that could result. Although from the sound of it that isn't going to be an issue.

Once you complete your tax return, then you should know exactly how much tax you will be required to pay and pay it earlier than submitting the return.

Note I have NEVER been in a position where I have had to do so, so I don't know the extent to which it is possible. 

... electronic payment...

What ever works for you and your family still in the US. 

Me, I would try to pay it myself using my US debit card and if, and only if, I had issues during the payment process, I would consider other options (including family). One would hope that the IRS payment gateway is set up in a way that is nice to overseas taxpayers... but I wouldn't hold my breath.


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## Bevdeforges

Just a note - I wouldn't use a card (debit or credit) if you can make a direct EFT from your US bank. But definitely make your payment from your US bank. It doesn't matter what the address is on the bank account, nor the address you use to file from. It's where the bank is located that counts.
Cheers,
Bev


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## sp84

Thank you so much for everything folks - you have no idea how much this thread has helped take me out of the dark (on a lot of matters)!

Just so that I don't keep harping on - I thought I would summarise my plans below:

(1) File for an extension (so that I can make use of FEIE)

(2) Have my tax returns prepared by April 15th in order to determine what I owe

(3) Pay what I owe by April 15th (via electronic transfer from my US bank)

(4) File my required FBAR (I am going to aim to file this by April 15th)

(5) Sit on my prepared tax return - then file once I am passed the allotted time being outside of the USA to qualify for FEIE

(6) Relax until Jan 2018 - then start to panic all over again? 

Everything there sound correct? or am I missing something?


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## sp84

Hey again everyone, 

I found this piece of information online tonight regarding filing US tax returns as a UK resident: _Americans living in the UK who earn over $10,000 a year (or $400 from self-employment) have to file a federal return declaring their world-wide income, and may have to pay US taxes_ ... _All US citizens and green card holders who meet the minimum income thresholds are required to file an annual federal income tax return_

Between June & December of 2016 (so when I moved to the UK and began working) - I did not earn $10k ... does that change anything about my situation? as in what I need to declare/what I need to file?

I know I have to file a US return for the first 6 months of the year (I have W2's etc showing my US based income)

Thanks folks!


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## Moulard

There are filing thresholds below which you do not need to file. 

If your filing status is single then you only have to file a return if your global gross income for the year was at least USD 10,300. But you need to consider all of your income for the US tax year both US and UK.

If you are owed a refund on taxes withheld you will still want to file even if your gross income was below the threshold

There is an interview page on the IRS website that may help you decide if you need to return.
Click the begin link on this page

https://www.irs.gov/uac/do-i-need-to-file-a-tax-return


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## Bevdeforges

Those are the simple, dead normal filing thresholds for everyone - whether living in the US or elsewhere. You cannot file a return just for the time you lived in the US - or just for the time you lived in the UK. It's an annual return and you have to file it for the entire calendar year, declaring your worldwide income.

The fact that you don't have W-2s for your UK earned income doesn't really make any difference. They more or less have to take your word for what you declare as your UK income - though you may have to fill out a FEC form if you're using a tax preparation software or other electronic filing method.
Cheers,
Bev


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## sp84

Bevdeforges said:


> Those are the simple, dead normal filing thresholds for everyone - whether living in the US or elsewhere. You cannot file a return just for the time you lived in the US - or just for the time you lived in the UK. It's an annual return and you have to file it for the entire calendar year, declaring your worldwide income.
> 
> The fact that you don't have W-2s for your UK earned income doesn't really make any difference. They more or less have to take your word for what you declare as your UK income - though you may have to fill out a FEC form if you're using a tax preparation software or other electronic filing method.
> Cheers,
> Bev


Thank you everyone - that was my mistake for misreading the quote from the IRS! Apologies !

I am having a little mini-meltdown today ... If you can remember I stated that I am a teacher here in the UK. So each month, the Department of Education deducts from my wages, for pension contributions. My understanding as you confirmed - is that it is a government based pension and therefore not an FBAR item.

Since I arrived here in July though - I have been working part time (1 or 2 days a week) in a local hotel. I had a look at my pay slips and noticed the terms "ee pension" (I think that stands for employee contributions) and "er"(for employee) ... Now, I never enrolled, or signed up for a private pension scheme through this part time job. I have heard of the term "workplace pensions" here in the UK and apparently by 2018 all companies have to offer them.

Little did I know - employers can apparently automatically enroll it's employees in a workplace pension. In 2016 my contributions towards this pension were £7 and my employers £8.

My questions are these:

(1) Does my TEACHER pension (although not an FBAR item) - have to be reported for FACTA purposes?

(2) Does my HOTEL pension (that I have known nothing about) - become an item that I have to declare on either FBAR or FACTA?

I am confused enough about the actual tax returns as is - never mind the rules regarding pensions! Any information at all about this would be much appreciated!

Cheers!


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## iota2014

Government pension funds are included under "NON-REPORTING UK FINANCIAL INSTITUTIONS AND PRODUCTS" in Annex II of the UK (IGA).
(https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/226267/8656.pdf)

To me that suggests the fund is not a "Specified Foreign Financial Asset", consequently no need to report on 8938.


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## sp84

iota2014 said:


> Government pension funds are included under "NON-REPORTING UK FINANCIAL INSTITUTIONS AND PRODUCTS" in Annex II of the UK (IGA).
> (https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/226267/8656.pdf)
> 
> To me that suggests the fund is not a "Specified Foreign Financial Asset", consequently no need to report on 8938.


Thanks iota - I assume that is for my Teacher pension?

I had a look on the gov.uk website in relation to work related pensions and it says the following:

Your employer must write to you when you’ve been automatically enrolled into their workplace pension scheme. They must tell you:

the date they added you to the pension scheme
the type of pension scheme and who runs it
how much they’ll contribute and how much you’ll have to pay in
how to leave the scheme, if you want to
how tax relief applies to you

Absolutely none of which has happened to me in the 9 months that I have worked at the hotel.

So in that case, I just have absolutely no idea where my "ee" and "er" pension contributions are going too


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## iota2014

sp84 said:


> Thanks iota - I assume that is for my Teacher pension?


Assuming you teach at a LEA school.

As for the deductions from your hotel wages - no idea. Why not ask the employer what it's for, and then you can probably opt out and get a refund if it's contributions to a pension plan you don't want.


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## sp84

iota2014 said:


> Assuming you teach at a LEA school.
> 
> As for the deductions from your hotel wages - no idea. Why not ask the employer what it's for, and then you can probably opt out and get a refund if it's contributions to a pension plan you don't want.


Cheers iota ! - Yea I am going to have to call them and figure out what is going on. 

I had to look up what an LEA was haha! Madness how the locally terminology in public sector schools changes within the UK. Yes I would teach in the equivalent of an LEA school here in Northern Ireland. The schools are governed by the local education authority and my wages are paid by the Department of Education in Northern Ireland (so a government based branch).


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## celticweb

I am enrolled in a work place pension. not a government one, just a work place pension. it's pretty common now when you're employed that you will be enrolled but yes you should be informed. we were all informed. it's not big deal dealing with them for US filing purposes if resident in the UK.

I filed the form 8833: Treaty-Based Return Position Disclosure. That tells the IRS that I am claiming a benefit under the US/UK tax treaty, I filed the form 8833, article 18 for the UK and IRS code 402 (b)

actually i was told (can't remember from where but most likely a tax preparer) that arguably I would not need to do this because the contributions are less than $10,000 - but generally thought to be more prudent to do so.

I assume all this was fine otherwise I would have heard something by now. I am not expert on this, just letting you know how mine was dealt with.


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## iota2014

sp84 said:


> Cheers iota ! - Yea I am going to have to call them and figure out what is going on.
> 
> I had to look up what an LEA was haha! Madness how the locally terminology in public sector schools changes within the UK.


Devolution. No longer a "local" education authority but an Education Authority in its own right. 



> Yes I would teach in the equivalent of an LEA school here in Northern Ireland. The schools are governed by the local education authority and my wages are paid by the Department of Education in Northern Ireland (so a government based branch).


Yes. A government pension.


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## sp84

celticweb said:


> I am enrolled in a work place pension. not a government one, just a work place pension. it's pretty common now when you're employed that you will be enrolled but yes you should be informed. we were all informed. it's not big deal dealing with them for US filing purposes if resident in the UK.
> 
> I filed the form 8833: Treaty-Based Return Position Disclosure. That tells the IRS that I am claiming a benefit under the US/UK tax treaty, I filed the form 8833, article 18 for the UK and IRS code 402 (b)
> 
> actually i was told (can't remember from where but most likely a tax preparer) that arguably I would not need to do this because the contributions are less than $10,000 - but generally thought to be more prudent to do so.
> 
> I assume all this was fine otherwise I would have heard something by now. I am not expert on this, just letting you know how mine was dealt with.


Cheers celticweb!

I'll have to find out exactly what I am enrolled in - as I haven't received any confirmation from the employer/documents from the pension provider.

So you didn't have to include your work based pension with your FBAR or file a FACTA?


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## Moulard

iota2014 said:


> Government pension funds are included under "NON-REPORTING UK FINANCIAL INSTITUTIONS AND PRODUCTS" in Annex II of the UK (IGA).
> (https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/226267/8656.pdf)
> 
> To me that suggests the fund is not a "Specified Foreign Financial Asset", consequently no need to report on 8938.


I may be mistaken, but my understanding is that these IGAs simply mean that the pension fund doesn't have to do a FATCA filing. Instead they report to the local taxing authority, and that taxing authority passes information to the IRS. 

Personal filing requirements are different.


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## iota2014

Moulard said:


> I may be mistaken, but my understanding is that these IGAs simply mean that the pension fund doesn't have to do a FATCA filing. Instead they report to the local taxing authority, and that taxing authority passes information to the IRS.


The point is, a government pension fund is exempt from reporting.



> Personal filing requirements are different.


The IRS has no reason to be interested in a UK resident's UK government pension. The employer contributions are exempt by treaty, the fund itself is exempt from FATCA reporting, and once retirement day arrives, the payments are exempt by treaty. 

Of course, there's nothing stopping the OP from filing 8833 to report the pension plan, if s/he wishes to do so..


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## celticweb

sp84 said:


> Cheers celticweb!
> 
> I'll have to find out exactly what I am enrolled in - as I haven't received any confirmation from the employer/documents from the pension provider.
> 
> So you didn't have to include your work based pension with your FBAR or file a FACTA?


My returns were done prudently because I had the intention of renouncing so wasn't going to cut any corners. I didn't have to file any Fatca forms for anything because I didn't meet the threshold.

I didn't file any other paperwork for the work pension but to be prudent we did file it on Fbar only. The UK is one of the better treaties as regards work pensions but at the same time, you could find people with differing opinions.

My position was make a treaty claim under Article 18 to exempt the contributions and growth from US tax and all growth is US tax-free. There are no trust form filing requirements on an arising basis. When you take the money out, you pay tax at income tax rates the same as any stateside pension.

However in your case there are so little contributions you could easily skip it if you were going to try to get enrolled out. But if you do make the 8833 treaty claim for the hotel pension work scheme, it really is no big deal. 

From what you described, the hotel pension thing sounds like a typical work place pension. my employer/employee contributions are pretty much 50% each for the year, for example mine £350, my employer £350. 
Hope this helps.


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## Bevdeforges

The other thing to consider is that if your pension is a "defined benefit" type of pension - i.e. you'll be paid some amount based on x years of salary after y years of service (even if that is combined with your work record elsewhere) - then it's not reportable for US purposes. There is no lump sum of cash that "belongs" to you.
Cheers,
Bev


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## iota2014

Bevdeforges said:


> The other thing to consider is that if your pension is a "defined benefit" type of pension - i.e. you'll be paid some amount based on x years of salary after y years of service (even if that is combined with your work record elsewhere) - then it's not reportable for US purposes. There is no lump sum of cash that "belongs" to you.


That's interesting. The Teachers' Pension is indeed a defined benefit pension, and unfunded at that. Filing Form 8938 would presumably mean filing zeroes?


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## Bevdeforges

iota2014 said:


> That's interesting. The Teachers' Pension is indeed a defined benefit pension, and unfunded at that. Filing Form 8398 would presumably mean filing zeroes?


You wouldn't file form 8398 unless your total foreign assets exceed the threshold amounts for overseas filers. (Something like $200,000 single, and $400,000 married filing jointly.) But if you have to file the form due to your other assets, a defined benefit pension simply isn't included in the assets you list - because it's not an asset. It's only a future right to payments. You don't actually "own" anything.
Cheers,
Bev


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## iota2014

iota2014 said:


> ... there's nothing stopping the OP from filing 8833 to report the pension plan, if s/he wishes to do so..


Correction - should read:



> ...there's nothing stopping the OP from filing *8938* [Statement of Specified Foreign Financial Assets] to report the pension plan, if s/he wishes to do so.


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## celticweb

Bevdeforges said:


> You wouldn't file form 8398 unless your total foreign assets exceed the threshold amounts for overseas filers. (Something like $200,000 single, and $400,000 married filing jointly.) But if you have to file the form due to your other assets, a defined benefit pension simply isn't included in the assets you list - because it's not an asset. It's only a future right to payments. You don't actually "own" anything.
> Cheers,
> Bev


That's right, this is why I said in my earlier post to the OP that I didn't have to file any Fatca forms because I didn't meet the threshold. The exact rule I think is for single filers is, $200,000 on the last day of the year or $300,000 any time during the year. 

My work place pension is defined benefit and that's how most of them are these days. i have no guarantee of anything, the fund can go up or down.


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## JustLurking

Bevdeforges said:


> But if you have to file the form [8938] due to your other assets, a defined benefit pension simply isn't included in the assets you list - because it's not an asset. It's only a future right to payments. You don't actually "own" anything.


In its Q&A for form 8938 the IRS suggests that you do in fact have to list the defined benefits pension, though when you do you can report its maximum value as zero.


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## iota2014

celticweb said:


> That's right, this is why I said in my earlier post to the OP that I didn't have to file any Fatca forms because I didn't meet the threshold. The exact rule I think is for single filers is, $200,000 on the last day of the year or $300,000 any time during the year.
> 
> My work place pension is defined benefit and that's how most of them are these days. i have no guarantee of anything, the fund can go up or down.


Isn't it the other way round? i believe the trend is *away* from defined benefit, and towards defined contribution.

Defined benefit pensions are very valuable, especially index-linked DB pensions. That is, as long as the payer survives and interest rates don't go negative. Defined contribution pensions are presumably much less expensive for the provider, since nothing is guaranteed.


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## iota2014

JustLurking said:


> In its Q&A for form 8938 the IRS suggests that you do in fact have to list the defined benefits pension, though when you do you can report its maximum value as zero.


Fortunately, for many normal, non-tax-evading, non-treaty-shopping CBT victims, valuing the pension plan at zero will mean there's no need to file the form at all.



> If you do not know or have reason to know based on readily accessible information the fair market value of your beneficial interest in the pension plan or deferred compensation plan on the last day of the year and you did not receive any distributions from the plan, the value of your interest in the plan is zero. *In this circumstance, you should also use a value of zero for the plan in determining whether you have met your reporting threshold.* If you have met the reporting threshold and are required to file Form 8938, you should report the plan and indicate that its maximum is zero.


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## celticweb

Yes Many do write the value as zero but most accountants will tell you if you get periodic statements to use the highest value of that for fbar purposes. for the Fatca form you would need to know the value the last day of the year or during the year if it was above the $300,000. this is for single, for married it's a higher threshold and if you live in the US, the threshold for single is $50,000 i think.

I actually put a value on my pension plan for the fbar. it's not difficult for me to find out. we have access to an online account at my work place so you can see the value and the contributions. even with the value used thankfully i was under the fatca reporting and now of course I am out of the system completely as a former citizen.


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## iota2014

celticweb said:


> Yes Many do write the value as zero but most accountants will tell you if you get periodic statements to use the highest value of that for fbar purposes. for the Fatca form you would need to know the value the last day of the year or during the year if it was above the $300,000. this is for single, for married it's a higher threshold and if you live in the US, the threshold for single is $50,000 i think.
> 
> I actually put a value on my pension plan for the fbar. it's not difficult for me to find out. we have access to an online account at my work place so you can see the value and the contributions. even with the value used thankfully i was under the fatca reporting and now of course I am out of the system completely as a former citizen.


That does suggest that your pension is defined-contribution, not defined-benefit. It's not easy to get a value for a DB pension, that's why the IRS says to use a value of zero.


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## celticweb

iota2014 said:


> That does suggest that your pension is defined-contribution, not defined-benefit. It's not easy to get a value for a DB pension, that's why the IRS says to use a value of zero.


Yes Iota you are right, mine is defined contribution. i get really confused with all these financial products so just as well I simplified my life now.

yes and that is what most of them are now, you pay in a percentage of salary that your employer matches and there is no guarantee of what the final payout will be when the time comes to take it out. thanks for pointing it out.


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## iota2014

celticweb said:


> Yes Iota you are right, mine is defined contribution. i get really confused with all these financial products so just as well I simplified my life now.
> 
> yes and that is what most of them are now, you pay in a percentage of salary that your employer matches and there is no guarantee of what the final payout will be when the time comes to take it out. thanks for pointing it out.


A sad sign of the times I guess. DB penefits do seem to be on the way out. And of course in the OP's case there is the whole question of whether NI will even continue to exist as a part of the UK. Still, no need to borrow trouble.


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## sp84

Bevdeforges said:


> You wouldn't file form 8398 unless your total foreign assets exceed the threshold amounts for overseas filers. (Something like $200,000 single, and $400,000 married filing jointly.) But if you have to file the form due to your other assets, _a defined benefit pension simply isn't included in the assets you list - because it's not an asset. It's only a future right to payments. You don't actually "own" anything.
> Cheers,_
> Bev


This is my understanding of my teachers pension - I am paying into a pot, with the idea that when I retire I will be entitled to a payment. I do not get any statements throughout the year to tell me the value of the pension; nor do I think the department of Education could even give me a valuation.

As a result of this - my understanding was that I do not need to report this pension on *ANY* form - including the FBAR. Is this correct?


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## Bevdeforges

sp84 said:


> This is my understanding of my teachers pension - I am paying into a pot, with the idea that when I retire I will be entitled to a payment. I do not get any statements throughout the year to tell me the value of the pension; nor do I think the department of Education could even give me a valuation.
> 
> As a result of this - my understanding was that I do not need to report this pension on *ANY* form - including the FBAR. Is this correct?


That's certainly how I see it. If the IRS has any questions, they'll be in touch. But don't hold your breath.
Cheers,
Bev


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## sp84

Bevdeforges said:


> That's certainly how I see it. If the IRS has any questions, they'll be in touch. But don't hold your breath.
> Cheers,
> Bev


Cheers Bev, 

I just got off the phone with teachers pensions - you were right in terms of: I pay a % of my wages each month into a "pot". When I retire, the amount I receive is based on an equation: average salary times years of service, divided by 80.

BUT!!! Apparently I should have been receiving a statement each year which tells me the value of the pension as of right now - even though I cannot withdraw any of it.

Does the fact that it holds a monetary amount (which is news to me as of 5 minutes ago) - change anything?


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## iota2014

sp84 said:


> Cheers Bev,
> 
> I just got off the phone with teachers pensions - you were right in terms of: I pay a % of my wages each month into a "pot". When I retire, the amount I receive is based on an equation: average salary times years of service, divided by 80.
> 
> BUT!!! Apparently I should have been receiving a statement each year which tells me the value of the pension as of right now - even though I cannot withdraw any of it.
> 
> Does the fact that it holds a monetary amount (which is news to me as of 5 minutes ago) - change anything?


Seems unlikely they're sending you an estimate of the fair market value of your pension, which is what the form asks for. It doesn't really *have* a FMV, since you can't sell it.

The E&W Teacher's Pension fund seems to just send a summary of contributions and service so far, and perhaps a calculation of how much you could expect to receive per month if you retired tomorrow. (See https://www.teacherspensions.co.uk/news/public-news/2015/02/annual-benefit-statement.aspx).

I took the view, when I was completing the 8538 after renouncing, that the FMV of my DB government pension was zero.


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## iota2014

Here you are:



> *Annual benefit statements*
> 
> The scheme manager must provide annual benefit statements to active members of DB public service pension schemes in accordance with any directions issued by HM Treasury or the Department of Finance and Personnel in Northern Ireland. The statement must include:
> 
> - a description of the benefits earned during a member’s pensionable service
> - any other information specified by HM Treasury or the Department of Finance and Personnel in Northern Ireland directions


Communicating to members | public service schemes | The Pensions Regulator

Not an estimate of the value of your interest in the pension.


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## 230724

Hi! What is the address of the blog post you referred to? Interested to read it!

-Mme


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## sp84

mmeprice said:


> Hi! What is the address of the blog post you referred to? Interested to read it!
> 
> -Mme


Hi Mme - which blog post are you referring too?


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## 230724

Sorry. I think I accidentally replied here. I was replying to someone else, and now I can't find that post! Whoops!


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## sp84

Hello again everyone, can I just confirm something - the FBAR to be filed this year is due on April 15th (well April 18th this year, in order to coincide with the date for tax returns); with an automatic extension until October 15th?

I still have to gather some information for my FBAR and won't have it ready by April 15th/18th - so in theory, if I file in say June for arguments sake, I will not be open to any penalties ?

Is that correct?

Thanks!


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## Moulard

Correct.

Here is the FINCen News Release on the change from Dec last year.

https://www.fincen.gov/news/news-releases/new-due-date-fbars-0


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## sp84

Moulard said:


> Correct.
> 
> Here is the FINCen News Release on the change from Dec last year.
> 
> https://www.fincen.gov/news/news-releases/new-due-date-fbars-0


Thank you Moulard that's fantastic! I just wanted to ensure that I had understood the wording correctly. So effectively - the *REAL* Fbar deadline is October 15th (surely it would make more sense to just say that)!?!?

It means I don't have to run around like a mad man over the next day or two trying to chase things up! Phew!


----------

