Several years ago, the Financial Crimes Enforcement Network (“FinCEN”) issued final regulations under the Bank Secrecy Act (“BSA”) regarding the “Report of Foreign Bank and Financial Accounts” (Form TD F 90-22.1, or “FBAR” subsequently changed to FinCEN Form 114).  On April 13, 2017, the Internal Revenue Service (“IRS”) published IR-2017-82 to remind FBAR filers that for the first time, the deadline for filing Form 114 is now the same as for a federal income tax return.  This means that filings for 2016 must be filed by April 18, 2017. We note that FinCEN grants filers who miss the April 18 deadline an automatic extension until October 16, 2017.  Please see the attached memo for further information.


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