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Posted

I see the old TD F 90-22.1 form has been replaced by FinCen 114. ATX says this form must be filed online only and is not available in ATX. They did provide a link for instructions. That took me to a website called BSA E-Filing System.

Has anyone done this? Should we as tax preparers enroll as filers on this system or just direct our clients to this site to do it themselves?

Form 8938 is still required to be filed with 1040 but has a higher threshold requirement than the FinCen 114.

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Posted

I never filed the old FBAR either. Too much risk in that one. I'd just make sure the clients know they have to file it. It wasn't a tax form either. The 8938 is a tax form, but at least has much higher limits than the FBAR, especially I'd you reside in a foreign country.

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