# US FBARs - Read the "fine" instructions!



## Bevdeforges (Nov 16, 2007)

Just a note to those of you who are concerned about filing FBAR declarations for employers' accounts you have signature authority but no financial interest over (may also apply if you're treasurer of a club or association, but you have to make your own call on that one):

RTFI (Read the fine instructions) for the FBAR (form TD F 90-22.1)

Just noted a new addition to the instructions for Part IV:

*Modified Reporting for United States Persons Residing and Employed Outside of the United States*

If I'm reading it right, they say you only have to fill out the part identifying the owner of the foreign account, but you can skip all the detail about balances and account numbers!

It always pays to give a good, healthy skim to the instructions - even if you've filled out the forms for years and years and think you know them by heart. You never know when they're going to slide something in on you like this.
Cheers,
Bev


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## Omater (Nov 26, 2011)

I am so glad to have found this information. Thank you Bev! I had read the instructions but I thought all information pertaining to this was on page 6 and I had indeed missed the modified paragraph. I have not worked for one particular Canadian corporation in a few years and I wasn't about to ask them for all their account info during the time I worked there. I know they wouldn't give it to me and I would not blame them. Again, thanks for the time you took to provide information such as this!


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## Peg (Sep 22, 2011)

Thank you very much Bev. And thank you Omater for bumping this as I am doing my 2011 FBARs this week.


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## terlinden (Nov 2, 2014)

*Club Accounts*

Re FBAR filings by club's officers it would also be helpful if Bev is right re "(may also apply if you're treasurer of a club or association, but you have to make your own call on that one)", i.e. "only have to fill out the part identifying the owner of the foreign account, but you can skip all the detail about balances and account numbers" - BUT my reading is that this/Part IV instructions - excerpted below - likely do(es) not apply to a Club's officers because it refers to "employer/accounts of the employer". 
- Elaine 
(excerpt of instructions' Part IV - Information on financial account(s) where filer has signature authority but no financial interest in the account(s))
... In addition, United States person who (1) resides outside of the United States, (2) is an officer or employee of an EMPLOYER who is physically located outside of the United States, and (3) has signature authority over a foreign financial account that is owned or maintained by the individual's EMPLOYER should only complete Part I and Items 34-43 of Part IV. ...


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## StewartPatton (Aug 5, 2014)

Nice update Bev. 

One additional note here--many of my clients are employed by entities they own, and this new provision doesnt change the score for these folks. If the employer is a company that a filer owns more than 50% of, then the filer is treated as owning the account, meaning that it is reported as an owned account instead of a sig authority account, so the new provision doesnt apply.


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