old FBAR query

[Catherine]

Client's spouse has had a couple of foreign accounts, always well under the limits for FBAR filings. However in reviewing some old records they were going to shred, he discovered that back in 2011 it's possible that one account went over the limit for less than a week. He will have to dig out old conversion rates and the detailed history of the account to see if it happened, or didn't quite happen, or just looked like it might have happened. 

Anyone know where I can look up whether or not FinCen wants a 12 year old FBAR filing and if so doing would open up a bigger can of worms?

[BrewOne]

Treasury requires you to file past six years to get back into compliance--I believe if they do not have a current issue with overseas accounts, then statute of limitation (5 years) applies?  [not a lawyer]

[Lee B]

Let sleeping dogs lie

[Gail in Virginia]

5 minutes ago, cbslee said:

Let sleeping dogs lie

For such a small potential filing requirement, and that far back, I agree.  

[BTS]

You forgot the "U" in Fubar   

[Abby Normal]

21 hours ago, BrewOne said:

Treasury requires you to file past six years to get back into compliance--I believe if they do not have a current issue with overseas accounts, then statute of limitation (5 years) applies?  [not a lawyer]

FBARs aren't filed with the IRS, but FinCEN is part of the US Treasury.

[Catherine]

Thanks to all. True, FBAR is FinCen not Treasury but back when they had their voluntary disclosure program, "compliance" was six years for that.  Client has not finished the research so I've still got some time to dither.