# Some last minute FBAR questions



## LondonResident (Sep 27, 2013)

Hi all.

I have three questions about an FBAR I am filling out:


I am the sole owner of a UK limited company (100% of shares). Which section do I put this in? In part 2 (Information on Financial Accounts Owned Separately) or part 3 (Information on Financial Accounts Owned Jointly) listing my company as Principal Joint Owner?
When paying rent, I made several transfers into an account and the same day transferred money to the landlord. My statement lists the end of day balance but should I include the maximum value before I transferred the money to my landlord?
I might have overpaid a credit card account. Do I need to add this form? It's a bit awkward as the only account ID number I have is my actual card number.

Many thanks for your help!


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## Bevdeforges (Nov 16, 2007)

FBARs are only for bank and investment accounts. You don't include any company you own - though if you have signature authority over the company's bank account (i.e. the account is in the company's name rather than in your name), then you report the account in the section for "accounts for which you have signature authority but no financial interest." (Yeah, weird, but that's how it works if the account belongs to the company rather than to you.)

Officially, you can use the highest balance to appear on any statement you received for the account (monthly, daily, whatever). If the maximum value didn't appear on a statement, I wouldn't worry about it. But you can always add a bit to whatever balance you decide to report, "just to be sure."

Credit card accounts are also not reportable for FBAR.
Cheers,
Bev


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## LondonResident (Sep 27, 2013)

Wow! Thanks for the quick reply.

I've moved the company account to the right section. For the company TIN, if I have an EIN, should I use that or put "Foreign" and input my UK registration number or some other number?

With regard to the maximum value of the account, I can't really see the harm of putting the higher of the two numbers (the balance before I paid my rent). It's around 3 times greater than the end of day balance so adding a bit doesn't really do anything.

I guess my point is that I'm constantly transferring funds between accounts and it's not like these maximum account values (and their sum) give an accurate portrayal of the maximum I had in all accounts at any one point in time. Is there any harm to playing it safe and putting the higher number?

Thanks!


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## BBCWatcher (Dec 28, 2012)

LondonResident said:


> For the company TIN, if I have an EIN, should I use that....


Yes. If there's a U.S. identifier (EIN in this case), that takes priority.



> With regard to the maximum value of the account, I can't really see the harm of putting the higher of the two numbers (the balance before I paid my rent). It's around 3 times greater than the end of day balance so adding a bit doesn't really do anything.


Yes, that's what you should report: the "high water mark" for the year.



> Is there any harm to playing it safe and putting the higher number?


None at all(*), but there is potential harm in underreporting.

(*) Assuming you are not laundering drug money, financing terrorism, profiting from human trafficking, funneling bribes to FIFA, etc., etc. If you're doing any of those things, then you have bigger potential problems.


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## solsol (Jun 25, 2015)

I was told by my accountant to use my SSN rather than the EIN, since I am the signer on the accounts.


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## Kriss2000 (Jun 27, 2015)

*Fbar question*

Hi

I'm filling out my fbar form and have also have a question about where to list my business account along side my personal accounts.

I don't have a limited company but I do have a small side business (self-employed tutor) and the account is under my business name and not my own. Do I also list this account under "accounts for which you have signature authority but no financial interest?" And then under the field for "title" do I just list myself as owner? This "title" is asked again at the end of the form by the signature section. Do I list myself as "owner" a second time even though I am listing both personal and a business account?

Also, as I don't have a U.S. identifier, do I just list foreign and the foreign business id?

Thanks for the help


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## BBCWatcher (Dec 28, 2012)

Kriss2000 said:


> Do I also list this account under "accounts for which you have signature authority but no financial interest?"


I don't know about the word "also" in your question, but yes, that's where you'd list such business accounts. They're not your individual accounts, they're not joint accounts, they're accounts over which you have signature authority. So that's where they go.



> And then under the field for "title" do I just list myself as owner?


Whenever you're asking a question about a form please provide the section of the form and the line number(s) you're asking about. I'm not quite sure what field(s) you're referring to. If you're referring to signature authority accounts line 43, you'd put your official title within that business. "Owner" is one option if truthful, yes.



> This "title" is asked again at the end of the form by the signature section. Do I list myself as "owner" a second time even though I am listing both personal and a business account?


I think you're referring to line 45 in the signature information section. Yes, that'll do.



> Also, as I don't have a U.S. identifier, do I just list foreign and the foreign business id?


I think you're back in the "No Financial Interest" section of the form (for signature authority accounts), lines 35 and 35a. Let's suppose the business is "Joe's Trucking Ltd." So on line 34 you'd put "Joe's Trucking Ltd." If Joe's Trucking Ltd. doesn't have a U.S. EIN, SSN, or ITIN (and is not required to have one) then you'd select "Foreign" in box 35a and you would enter the foreign tax identification number. For example, that could be the Italian VAT (IVA) registration number for Joe's Trucking Ltd. if it is an Italian business.


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## LondonResident (Sep 27, 2013)

Returning to this several years later, I ended up put these bank accounts in Part II. I didn't mention in the original post that the company is classified as a disregarded entity. I asked my accountant before I filed and they said because of that, I can put it in Part II instead of Part IV.

From this year, the company will be re-classified as a foreign partnership. When I file my 2020 FBAR (in 2021, of course), should these go into Part IV? For my 2019 FBAR, I plan to continue to put them in Part II,

Thanks.


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## Bevdeforges (Nov 16, 2007)

My, this is an old thread....

If your business is becoming a partnership, I would think it the bank account might go into Section 3 - for "jointly held" accounts. (Assuming your partners have some level of signing authority or ownership.)


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## LondonResident (Sep 27, 2013)

Thanks for your help, as always! I did a search on the site and my own thread came up 

It looks like I'll need to ask my accountant next year. They advised me on the partnership change so I'll ask about this even though I file my own FBAR.


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## LondonResident (Sep 27, 2013)

By the way, you were right @Bevdeforges (of course!)


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