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Who must file an FBAR?
Any United States person who has a financial interest in or signature authority or other authority over any financial account in a foreign country, if the aggregate value of these accounts exceeds $10,000 at any time during the calendar year. See also Notice 2010-23.
Make sure you contact IRS before the IRS contacts you!
Overview for FBAR
The Financial Crimes Enforcement Network (FinCEN) delegated to IRS its enforcement authority for penalties imposed under Title 31, Sections 5314 – 5321 for the failure to file Form TD F 90-22.1 Report Of Foreign Bank And Financial Accounts (FBAR) .
Form TD F 90-22.1 , Report of Foreign Bank and Financial Accounts, must be filed by US persons who have a financial interest in, signature authority, or other authority over one or more financial accounts in foreign countries with an aggregate value exceeding $10,000 at any time during the calendar year.
If you failure to file this form it could result in civil and or criminal penalties. The civil penalties may be appealed. Should the case go criminal it will be a long hard road.
FBAR penalties may come to Appeals as stand-alone cases or together with a related income tax or international penalty.
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