# Too early for FBAR?



## Alltimegreat1 (Feb 25, 2015)

Is it too early to submit an FBAR for 2016? Do I need to wait for some official IRS exchange rate to be published?


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## Bevdeforges (Nov 16, 2007)

Nope - the FBAR forms allow you to indicate the year you are filing for. And we're certainly past the end of the year, so you should know the high balance (or be able to determine it from your bank statements).

You can use any publicly available exchange rate - from a bank or FX company - and you don't have to wait for the IRS or Treasury charts to come out. (Ideally, if your high balance occurs on a specific date, you "should" use the exchange rates for that date. But no one does it like that.) Just make a note of what exchange rate you use on the off chance that they come back with questions.
Cheers,
Bev


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## ForeignBody (Oct 20, 2011)

Bevdeforges said:


> You can use any publicly available exchange rate - from a bank or FX company - and you don't have to wait for the IRS or Treasury charts to come out. (Ideally, if your high balance occurs on a specific date, you "should" use the exchange rates for that date. But no one does it like that.) Just make a note of what exchange rate you use on the off chance that they come back with questions.
> Cheers,
> Bev


I'm not sure why you keep saying this. The FBAR instructions specifically say to use the *Treasury Rate of Exchange for December 31*, and these are available here:

https://www.fiscal.treasury.gov/fsreports/rpt/treasRptRateExch/currentRates.htm


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## iota2014 (Jul 30, 2015)

ForeignBody said:


> I'm not sure why you keep saying this. The FBAR instructions specifically say to use the *Treasury Rate of Exchange for December 31*, and these are available here:
> 
> https://www.fiscal.treasury.gov/fsreports/rpt/treasRptRateExch/currentRates.htm


What difference does it make?

The IRS no doubt has to state what exchange rule should be used but why on earth would they care, provided it doesn't reduce tax paid?


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## ForeignBody (Oct 20, 2011)

iota2014 said:


> What difference does it make?
> 
> The IRS no doubt has to state what exchange rule should be used but why on earth would they care, provided it doesn't reduce tax paid?


If we are going to advise people isn't it best to give advice as per IRS instructions or is it just a free for all to say whatever we think?

On some matters there are uncertainties where a range of opinions are helpful. On this one it is precise.


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## Bevdeforges (Nov 16, 2007)

The FinCEN instructions go on to say:



> If no Treasury Financial Management Service rate is available, use another verifiable exchange rate and provide the source of that rate.


We can debate the precise meaning of the word "available" - but this does seem to indicate that using a standard verifiable published rate will do the trick.
Cheers,
Bev


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## iota2014 (Jul 30, 2015)

Personally I think this forum, and Bev especially, provides a welcome breath of reality as opposed to the IRS terror tactics that give the impression the IRS knows all and you could be fined thousands for something as trivial as using a different exchange rate. It doesn't seem to me it makes a bit of difference what exchange rate is used, as long as tax due is unchanged. 

Most FBAR aggregated balances are completely meaningless anyway, other than as a signal to the IRS that the filer's not worth wasting time on. If the IRS/FINCEN want to make an issue of the exchange rate they can do what they should have done from the start - tell the taxpayer to enter the amount without converting it, and then the IRS can use whatever rate they please.


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