Not-for-Profit Notebook

Practical insight and analysis on the accounting, audit and tax issues impacting not-for-profit organizations.

Important Information About FinCEN Form 114 For Not-For-Profit Organizations

tax_formsThe Financial Crimes Enforcement Network (FinCEN), a bureau of the U.S. Department of the Treasury, requires the annual filing of FinCEN Form 114, Report of Foreign Bank and Financial Accounts, by organizations that had an interest in, or signature or other authority over, financial accounts having an aggregate value exceeding $10,000 in a foreign country at any time during the calendar year reported.  Financial accounts include bank accounts, brokerage accounts, mutual funds, trusts, or other types of foreign financial accounts.  Keep in mind that the FinCEN Form 114 supersedes the prior Form TD F 90-22.1.

This filing requirement applies to taxpayers that have direct or indirect control over a foreign or domestic entity with foreign financial accounts, even if the taxpayer does not have foreign account(s).  For example, an exempt organization-owned foreign account would require filings by the exempt organization and by the individual officers with signature authority.  Those officers with signature authority would also be required to disclose such on their individual Form 1040 for the year.

Further complicating the reporting requirement is the fact that the FinCEN Form 114 must be e-filed by June 30 each year with no available extension.

If you fail to disclose the required information to the U.S. Department of Treasury, the failure to disclose may result in substantial civil and/or criminal penalties.

If you think that you may have a FinCEN Form 114 filing requirement, or you aren’t sure, contact us as soon as possible so that we may assist you.