PUBLIC SUBMISSION

As of: 1/15/21 1:32 PM
Received: January 15, 2021
Status: Non_Public
Tracking No. 1k5-9l8f-hsmf
Comments Due: January 15, 2021
Submission Type: Web

Docket: FINCEN-2020-0013
Agency Information Collection Activities; Proposed Renewal; Comment Request; Renewal Without Change of Reports of Foreign Financial Accounts Regulations and FinCEN Report 114, Report of Foreign Bank And Financial Accounts

Comment On: FINCEN-2020-0013-0001
Agency Information Collection Activities; Proposals, Submissions, and Approvals: Renewal Without Change of Reports of Foreign Financial Accounts Regulations and FinCEN Report 114, Report of Foreign Bank and Financial Accounts

Document: FINCEN-2020-0013-DRAFT-0051
Comment on FR Doc # 2020-25216


Submitter Information

Name: Roseanne Sherman
Address:

Giannaki Tziovani 6
Frenaros,  Cyprus,  5350

Email: roseannesh@yahoo.com
Phone: +35797699064

General Comment

FBAR reporting is quite difficult considering it is required for accounts containing more than $10,000 at any time during a year. $10,000 is a very low threshold for this kind of reporting. If the Dept of Treasury is concerned about money laundering or tax evasion, certainly $10,000 would not fall into these categories. The limit should be raised to $250,000 or more.

Additionally, FBAR reporting has created problems in opening bank accounts in foreign countries. Foreign countries do not want to deal with the onerous reporting that the US requires and would prefer just to not open bank accounts for Americans who live abroad. This creates all kinds of problems for Americans who live abroad, not the least of which is related to residency permits. If an American cannot open a bank account in the country they live in, they are often unable to get a residency permit that often requires a certain amount of money in a bank account in that country.

No other country requires reporting similar to FBAR. I would prefer that it be eliminated. But if that is not the case, then the threshold should be raised significantly.