ANNOUNCEMENT
Fincen, after posting on their website that the FBAR would be due on 12/31/20, removed the link to that extension. Now the ‘extension’ only applies to victims of the ‘recent natural disasters’
(outdated information) - An update to the deadline to file your 2019 FBAR was announced on 10/14/20. The 2019 FBAR deadline has been extended to December 31st, 2020. This announcement comes one. full. day. ahead of the original filing deadline.
It’s great that this deadline has been extended but this extension could have been decided and communicated to taxpayers much sooner. I also doubt that many taxpayers are going to find their way over to the BSA website which hosts this announcement: (https://bsaefiling.fincen.treas.gov/Notice.html)
This FBAR extension comes one day before the IRS sent out “Tax Tip 2020-137: Most taxpayers who requested an extension to file must file today”. Again, I know advance notice isn’t their strong suit, but maybe consider sending this reminder a little earlier than 10:10 AM on the day of the deadline. Especially since 10:00 AM EST on October 15th is 1:00 AM on October 16th for many U.S. citizens in Australia.
For most individuals with foreign accounts and assets, the potential FBAR exposure greatly exceeds the potential tax return exposure. In that light, the FBAR extension could really help taxpayers to avoid gigantic penalties.
The pandemic isn’t generating the same amount of fear in October that it was causing in March and April, but there is no doubt that a number of individuals will have their ability to file their returns impaired by the Coronavirus. I expect that the IRS will be offering relief to individuals that have their ability to meet their filing obligations directly impacted by Covid-19, but, as someone who has argued reasonable cause in a large variety of circumstances, it never surprises me when the IRS tries to take a hard line approach to the application of penalties.