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FinCEN and FBAR

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    FinCEN and FBAR

    I am new to these and am hoping that I properly identified this from what I read.

    I believe that since my clients (a married couple), each opened separate accounts in a foreign country (the same country but different banks) and had over $150,000 total, they will need to file both forms.

    Since they file jointly, they can file Form 8938 jointly, even though none of the accounts are held jointly.

    However, since they have separate accounts, each of them will need to file a separate FinCEN 114 form.

    Am I correct in the above analysis?

    I am still gathering information from them including the details that they do not yet have about the maximum in each account.

    As I understand it, filing a Federal extension would likewise extend the due date for Form 8938. It appears that I do not need to do anything to extend the deadline for the FinCEN 114 form to October. Is this accurate?

    Are there any things i should look out for in these filings?

    Thank you all.
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