The June 30 deadline is rapidly approaching to file the FBAR reports for overseas bank accounts on which you have signature authority when the account holds $10,000 or more at any time during the year.
For mission organizations, think about those checking accounts you have in the field used to fund your local activities. If those accounts have more than $10,000 in them at any point during the year your organization has a filing requirement.
If you are in the finance area and have signature authority on one of those accounts, you personally have a filing requirement.
There’s no extension for the deadline. The penalties could get nasty.
Kelly Phillips Erb provides a great summary: IRS Issues Reminder As Taxpayers Near Deadline To Report Foreign Accounts, Assets.
Here is her technical summary:
Who has to file an FBAR? If you are a U.S. person with a financial interest in or signature authority over a foreign financial account, including a bank account, brokerage account, mutual fund, trust, or other type of foreign financial account, and the total of all of those accounts is greater than $10,000 at any time during the year, you need to report.
Here is my casual summary:
You personally need to file a report (called and FBAR) with a specific federal agency (acronym FinCEN) if you can sign on an overseas account if the balance is over $10,000 at any time in the year. This applies to the charity you work for as well.
The purpose of this filing requirement is to catch people evading income tax by hiding money overseas. Like it or not (and you probably don’t) the rules also applies to ‘entities’ who have accounts outside the United States. The ministry you work for is an ‘entity’, thus the rules apply.
To motivate individuals to report all their overseas cash, and thus report all their earnings for income tax purposes, the penalties are severe. From the article:
Failure to timely report, if non-willful, could result in a penalty of up to $10,000 for each omission. If the failure is considered willful, a penalty of up to the greater of $100,000 or 50% of account balances could apply – again, for each year of omission. More concerning, criminal penalties may also apply.
There is an additional form that must be filed if the amount of assets are over $50,000 at the end of the year or over $75,000 at any one time during the year. (I didn’t realize that until today. Yeah, I’m always learning new stuff. That’s a major reason I blog.)
The feds are actively prosecuting individuals who hide huge piles of cash overseas. Some big-time evaders are actually going to jail.
Yes, yes, I hear you thinking “...but, but, but, we are a little mission-sending organization working in Asia or Africa – we aren’t laundering money or cheating the IRS – we just need that account to get funds overseas so our staff can do our good work.”
I get it. I really do. Keep doing your good work. While doing so you really, really need to get those forms filed if you have over 10 grand in all of your accounts on any one day in the year.
If this is new information for you, please read the linked article. And get those forms filed.