Do you use an overseas bank account in your ministry? Then you may have a filing requirement for that account.

If your ministry uses an overseas bank account to further your mission, you may have a requirement to file a report called an FBAR if the balance is over a certain amount at any point in the year.

Even worse, if individuals in your organization, like you Ms. CFO or Mr. Treasurer or Mrs. Program Manager, have signature authority over that account, the individuals have a requirement to disclose that authority on their personal 1040. The individuals may also need to file an FBAR individually.

If you want a convenient place to start figuring out your duties, check out an article in the Journal of Accountancy, What to do when a client has an undisclosed foreign account.

The IRS is putting a lot of emphasis on finding those accounts. Those accounts are often used to hide income and thus evade income taxes. The IRS’ goal is obviously to chase down tax cheats.

Most of the article talks about an individual who has undisclosed income in an overseas account, but the first part and the background applies to ministries.

The side effect of the increased effort is that some ministries could possibly become visible as nonfilers. Since regulators sometimes read my blogs, I just need to point that the innocuous use of a foreign account to further ministry could still generate a filing requirement, even though there is no income tax being evaded and no intend whatsoever to hide money.

I have several other posts on this issue, which you can find by clicking to this tagged search.

Yes, yes, I know this is just one more thing to do in your already overloaded schedule.  Remember that rendering unto Caesar what belongs to Caesar and to God what belongs to God means we are obligated to follow the lawfully enacted rules of the land unless such laws violate the Scripture.  Reporting your overseas cash to the Treasury Department does not fall into that exception.

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