The Treasury Department's Financial Crimes Enforcement Network (FinCEN) announced an automatic six-month extension for taxpayers required to file FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR). Taxpayers now have until October 16 to submit their FBARs for 2016 without being subject to penalties.
FBAR Overview. Subject to certain exceptions, any United States person with an interest in, or signature or other authority over, one or more foreign financial accounts whose aggregate value exceeds $10,000 at any time during a calendar year is required to file an FBAR in the following year.
Automatic Extension of Filing Deadline to October 15. Until last year, FBARs were generally due on June 30, with no automatic extensions available. In 2015, Congress moved the deadline to April 15 beginning with FBARs for 2016 (due in 2017). Congress also provided for extensions of up to six months. To reduce the administrative burden and facilitate compliance, FinCEN is granting all filers an automatic extension to October 15 every year, without the need for specific requests, until further notice. Thus, FBARs for 2016 may be submitted as late as Monday, October 16.
Automatic Extension Only for FBARs. This automatic extension is limited to FBARs. The deadline for most IRS returns for foreign assets will not be extended unless the taxpayer files an extension request with respect to the underlying tax return. This includes IRS Form 8938 (Statement of Specified Foreign Financial Assets), IRS Form 5471 (Information Return of U.S. Persons With Respect to Certain Foreign Corporations), IRS Form 8865 (Return of U.S. Persons With Respect to Certain Foreign Partnerships) and IRS Form 8621 (Information Return by a Shareholder of a Passive Foreign Investment Company or Qualified Electing Fund), among others. IRS Form 3520 (Annual Return To Report Transactions With Foreign Trusts and Receipt of Certain Foreign Gifts), although filed separately from the filer's tax return, is due at the same time as the filer's tax return, including extensions.
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The ABA recently published the 25th Edition of The Property Tax Deskbook.
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Day Pitney Press Release
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Day Pitney Press Release
Day Pitney LLP represented Pula Capital Management LP (Pula), a newly formed investment manager based in Virginia, in connection with (i) the acquisition of a minority ownership interest in Pula by Felton Group, LLC (Felton Group), and (ii) an investment by Felton Group in Pula Capital Fund, LP, a newly formed fund managed by Pula that intends to employ novel mathematical techniques and a proprietary, systematic predictive model to trade a diversified long-short portfolio of liquid U.S. equities.