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Understanding FBAR Disclosure Responsibilities


When Does an Entity Itself Need to File?

Under the FBAR regulations—31 CFR 1010.350—an FBAR must be filed by a United States person with a financial interest in, or signature authority over, a bank, securities, or other financial account in a foreign country. (It is worth noting that a foreign insurance policy or annuity falls within the definition of “other financial account,” as does an interest in a foreign mutual fund.) A United States person will be deemed to have a financial interest in an account when, among other things, the United States person is the owner of record or holder of legal title of the account.

Understanding FBAR Disclosure Responsibilities