# What to do? - past FBARS nominally over the limit



## Jacharchi (Sep 2, 2014)

I'm a bit shocked and worried that I have only now just realized that I probably needed to file these FBARs... I have lived abroad in Turkey for years. I have filed my US taxes every year even though I have the foreign income credit so I never owe tax. I have an offshore life assurance account at Isle of Man and the cash value became just over 10k in 2010 and is this year only worth 14k. I am willing to comply with the requirements to file, but do I also need to amend each of my 2010-2013 tax forms too just to declare this account and paltry amount?? Or is filing the FBARS going to be enough? incidentally I have surrendered the account and it will be transfered to my Turkish bank account within a few weeks, which will put my Turkish account over the 10k threshold (for the first time). Should I just wait and file for this amount next year and just forget about the rest? Is that a risk? 
Thanks in advance for any advice


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## Bevdeforges (Nov 16, 2007)

Have moved you out into a thread of your own to try and get a variety of opinions and experience here.

Frankly, if the sum total of all your accounts is only slightly above the $10,000 mark, I'd just file going forward and let it go with that. Yes, the penalties sound scary and all, but for small potatoes like this, they probably aren't going to hassle you for the back filings.

I wouldn't bother amending your previously filed returns in any event. Certainly up until now, they don't seem to track between your FBAR filings and your tax returns. That could change in the future, but until then I wouldn't worry about it.

I do think, however, that there are other points of view on this subject.
Cheers,
Bev


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## BBCWatcher (Dec 28, 2012)

I'd take a look at the IRS's new and improved streamlined program to see if it makes sense to use that for this oversight. That'd be a low or zero cost way to get this issue completely behind you, by the books.


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## DavidMcKeegan (Aug 27, 2012)

I think your best bet will be to just file the past FBAR's (from 2010 to 2013 from the sound of it) and then properly report the account on your tax returns moving forward (also continue to file FBAR's).

We have caught up hundreds of people who were behind on their FBAR's only (had been filing their taxes), and have yet to see any negative consequences come from that. I would definitely back file and take advantage of the leniency in place currently. 

Also, remember that the FBAR reporting is based on the total of all accounts. As such, even if just one of your accounts is over the 10K threshold, you will have to report all accounts as your total is now above 10K.

I hope this helps!


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## someNri (Jun 12, 2014)

Jacharchi said:


> I'm a bit shocked and worried that I have only now just realized that I probably needed to file these FBARs... I have lived abroad in Turkey for years. I have filed my US taxes every year even though I have the foreign income credit so I never owe tax. I have an offshore life assurance account at Isle of Man and the cash value became just over 10k in 2010 and is this year only worth 14k. I am willing to comply with the requirements to file, but do I also need to amend each of my 2010-2013 tax forms too just to declare this account and paltry amount?? Or is filing the FBARS going to be enough? incidentally I have surrendered the account and it will be transfered to my Turkish bank account within a few weeks, which will put my Turkish account over the 10k threshold (for the first time). Should I just wait and file for this amount next year and just forget about the rest? Is that a risk?
> Thanks in advance for any advice


Option #4 may apply to you. No amendments.

Options Available For U.S. Taxpayers with Undisclosed Foreign Financial Assets


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## Jacharchi (Sep 2, 2014)

Thanks everyone for your thoughts. I think I will go ahead and file the Fbars for 2010-2013. At least that way it's on file even though it's late. I haven't decided what to do about amending the returns... On the original returns I checked the box about having foreign bank accounts, but didn't specifically name this account because I thought it was just for bank accounts, not this life assurance account. It's such a little amount that I don't need to pay taxes on it. So amending them would only add the name of the country where the account is located to the amended return, which seems rather unnecessary considering the fbar will have that information and more details about the account number and amount, etc. and of course, going forward I will be sure to do the tax return correctly as well.


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## ForeignBody (Oct 20, 2011)

I would file the FBARs and leave it at that. The FBAR website provides for late filing and gives you a choice of reasons. From the information you give you are hardly in the realm of international tax evaders!


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## Jacharchi (Sep 2, 2014)

Just an update... I found an online IRS email tax assistance service. I wrote them over a week ago and they only today replied  anyway, while they said they couldn't really answer any questions related to the FBARs and directed me to ask my questions to FINCEN, they did write the following: 

"The FBAR filing is not part of your federal income tax filing. Therefore, you should not file amended returns for tax year 2010-2013 when filing FBAR for those years."

So, I filed the past FBARs but will not have to file any amended returns.. Thank goodness!
Cheers


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