PUBLIC SUBMISSION

As of: 1/15/21 2:23 PM
Received: January 15, 2021
Status: Non_Public
Tracking No. 1k5-9l8j-2oej
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-0068
Comment on FR Doc # 2020-25216


Submitter Information

Name: Rachel Eugster
Address:

109 Bayswater Ave.
Ottawa,  Ontario,  Canada,  K1Y 2G2

Email: rachel.eugster.dpca@gmail.com
Phone: 613-798-1301

General Comment

Re: Docket No. FINCEN-2020-0013, OMB control number 1506-0009
I am an American citizen living in Canada who diligently files tax returns in both the U.S. and Canada every year.
The requirement to file these documents annually is designed to capture whales. While it may do so, it also brings up millions of innocent minnows in the process. For law-abiding, tax-compliant citizens living abroad, the filing requirement is onerous to the point of being punitive, as it adds layers of paperwork and record-keeping and, for many, the necessity of hiring professional accountants. This is unfair to people earning low-to-relatively modest salaries.
The process is also very poorly designed to collect data with any accuracy.
To name but just one of the many issues I have had: In a year when I undertook renovations on my home, I borrowed money from my line of credit. For reasons I no longer remember, this sum landed in my savings account and was then transferred into my checking account within the same year. Thus, on my FBAR reporting that year, the same dollars--which were borrowed and therefore not even mine--got doubly reported, as they inflated the highest-balance totals in both my savings and my checking account.
This makes no sense.
I urge you to change the requirements to create exemptions from filing these forms for tax-compliant citizens with relatively modest holdings.