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14648: FinCEN 114 - Frequently Asked Questions


Fed Returns Generally

Choose from the following frequently asked questions about Form FinCEN 114: .
 

About Form FinCEN 114

The FinCEN Report 114, Report of Foreign Bank and Financial Accounts, is required if a taxpayer meets the following requirements:

  1. The United States person had a financial interest in or signature authority over at least one financial account located outside of the United States; and
  2. The aggregate value of all foreign financial accounts exceeded $10,000 at any time during the calendar year reported.

Note: FinCEN Form 114 is filed separately from the federal and state returns. Unlike tax forms that are filed with the IRS, the FinCEN Form 114 report is e-filed with the United States Department of the Treasury as part of the Bank Secrecy Act (BSA). 

For more information see Drake Software FAQs.

To accommodate the extensions detailed in FinCEN Notice 2018-1, Drake Software will continue to support 2017 filings of the FinCEN Form 114 report concurrently with 2018. 2017 reports must be completed and transmitted in the 2017 software and the 2018 report must be completed and transmitted in the 2018 software. 

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Due Date

The FBAR filing deadline follows the Federal income tax due date guidance, which notes that when the Federal income tax due date falls on a Saturday, Sunday, or legal holiday, a return is considered timely filed if filed on the next succeeding day that is not a Saturday, Sunday, or legal holiday. Taxpayers are allowed an automatic extension to October 15 if they fail to meet the FBAR annual due date of April 15. There is no need to request an extension to file the FBAR. 

For more information or additional extensions, see the IRS FBAR page

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Record Retention Requirements:

The records must be retained for a period of 5 years from June 30th of the year following the calendar year reported. Those records must be available for inspection as provided by law. Retaining a copy of the filed FBAR can help to satisfy the record keeping requirements. For more information on record keeping, see the FinCEN.gov website.

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Preparing and E-filing through Drake Tax:

Follow these steps to prepare and e-file the form through the current year of Drake Tax:

Note: Prior year e-filing is not supported through Drake Tax with the exception of the 2017 filings (indicated above). 2013-2016 Forms FinCEN 114 must be filed through the BSA website and not through Drake Tax. 

  1. Open screen FRGN, available from the Foreign tab of the Data Entry Menu, and enter specific account information.
  2. Make a selection from the Account is for drop list for each account. Press Page Down to open a new screen for each account.
    • The foreign account screens and information will be updated to next year unless the Do not update box is marked. 
  3. Close screen FRGN and open screen 114 (also available from the Foreign tab). Complete all necessary fields.
    • The signature date field on the 114 screen must be the current date to allow e-file (FBAR Message 1466). 
  4. Mark the FinCEN Form 114 is ready for transmission check box at the top of the screen.
  5. View the return (press Ctrl+V or click View from the toolbar) and review any EF messages on the FBAR Messages Pg.
    • Errors on the MESSAGES page are not required to be cleared before e-filing the FinCEN 114; only FBAR Messages prevent e-filing of the FinCEN 114. 
  6. Return to data entry and clear any EF messages related to FinCEN 114. 
  7. Open screen EF (available from the General tab of the Data Entry Menu), and mark the FinCEN 114 only check box.
    • The FinCEN 114 cannot be transmitted with any other federal or state return type in the same transmission. The FINCEN 114 must be transmitted separately.
  8. From the Home window of Drake Tax, go to EF > Select Returns for EF, and select the FinCEN report.
  9. Proceed through the usual procedure for e-file submissions.
  • Important: If the FinCEN Form 114 was not filed by the due date (or extended due date), the applicable Late-filing reason should be chosen on the114 screen.
    • If choosing Z - Other, you must also attach a statement by using the SCH screen, statement number F14

    Note: The late filing reason is produced in the FinCEN 114 return as Form 114 pg 6. If the late filing reason is a selection other than Z - Other, an SCH screen statement will not be included with the FinCEN return.

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Receiving Acknowledgments:

  • Once filed, it takes at least 24 - 48 hours for acknowledgments to come back from the BSA. The BSA does not currently process filings on holidays or weekends. 
  • Acknowledgments (acks) for FinCEN 114 are received in the same manner as other acks in Drake Tax.
  • If the e-filed return receives a reject, Drake Software will contact you and guide you through the steps for correcting and re-submitting the form.
  • There is no perfection period for the FinCEN Form 114. If the FinCEN comes back with a warning/reject, you must make corrections within the correction period, which is 30 days.

See the BSA Electronic Filing Requirements for further information.

EF message 1468

FBAR EF message 1468 states:

Incomplete Late Filing Reason: A selection of "Z - Other" has been made in the "Late filing reason" drop list on screen 114, but the required explanation has not been completed. Using screen SCH, make a selection of "F14" from the drop list and type an explanation. 

Both a selection of F14 and an explanation are required to be entered on the SCH screen. If the FinCEN 114 is for the spouse you must select S in the TSJ box and enter a Multi-form code of 2 on the SCH screen that is being used to explain why the spouse is filing their FinCEN 114 late.  

Can I e-file an amended FinCEN 114 through Drake Tax?

Yes, to e-file an amended FinCEN 114 through Drake Tax, Follow these steps:

  1. Go to the 114 screen and check the Amended box.
  2. Enter the Prior report BSA identifier (or all zeros if your BSA identifier is unknown).
  3. Make any other necessary changes to the report.
  4. Recalculate and re-transmit the FinCEN 114 to the BSA. 

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