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Do you have a financial interest in or signature authority over a foreign financial account, including a bank account, brokerage account, mutual fund, or other type of foreign financial account? If you do, and certain thresholds are met, then filing of FinCEN Form 114 Report of Foreign Bank and Financial Accounts will be required to avoid substantial penalties.

US citizens, US residents and entities such as corporations, partnerships and limited liability companies are required to file the FinCEN report if they had a financial interest in or signature authority over at least one financial account located outside of the United States and the if the aggregate value of all foreign accounts exceeded $10,000 at any time during the calendar year reported.

The FinCEN filing is a calendar year report filed separately from any other tax returns you may file and applies whether or not the financial account produced taxable income. The FinCEN filing requirement is in addition to other required reporting of foreign financial assets, such as Form 8938 Statement of Specified Foreign Financial Assets, which is filed with along with an individual's Form 1040 return. The deadline for filing the calendar year 2015 Fin CEN report is quickly approaching and must be filed by June 30, 2016. There is no provision for requesting an extension of time to file. Failure to file penalties can be up to $10,000 per violation. If the failure is considered willful then the penalty increases to the greater of $100,000 or 50 percent of the balance in the account at the time of violation.

If you have an interest in or signature authority over a foreign account and have not filed your 2015 report, prior year reports, or would like more information, contact your local UHY LLP professional.