The IRS has a major push underway to identify people who have hidden cash overseas to avoid paying taxes. That enforcement effort is obviously not a big deal to the nonprofit community.
However, the reporting requirement still applies to ministries that have cash located in their overseas programs.
Here’s the issue: If an individual or organization has ownership or signature authority in an overseas bank account that goes over a mere $10,000 at any point during the year, there is a report that has to be filed by June 30 of the following year.
Even though the severe penalties are intended to encourage people to report all their taxable income, those filing requirements and heavy penalties could create serious problems for an NPO.
If your ministry has cash located overseas, you really need to pay attention to this reporting requirement.
Here is some background that the IRS sent out today in an e-mail update to NPOs:
Helpful information for Report of Foreign Bank and Financial Accounts (FBAR) filings.
- The filing deadline for FBARs is June 30, 2012, no exceptions.
- FBAR filings must be received by June 30, not post-marked.
- FBAR e-file is now available.
- Where do you file FBAR?
- IRS offers an email address for your FBAR inquiries: FBARquestions@irs.gov
- Need FBAR and Title 31 assistance? Contact the IRS helpline from within the U.S. or from abroad.
If you can not meet the 6-30 filing deadline, I would encourage you to get tax counsel and then seriously consider getting the reports filed as soon as you can.
For more background, see articles I wrote last year, which you can find in part one, part two, part three, and part four.