Snapshot in time: Eyewitness account of evolution of Schedule B and the #FBAR Form TDF 90-22.1 from 1981 to 1986

The above tweet references a fascinating discussion about Mr. #FBAR in the early years prior to the “The FBAR Fundraiser“.

Interestingly for the years 2003 to 2008 (if memory serves), IRS Publication 54 did NOT reference the FBAR requirement.

OAP says
October 11, 2016 at 4:23 pm

@heidi, @pacifica777

Now you’ve peaked my curiosity, and I’ve done a sad thing. My first filing from abroad was in 1981 and I’m sure I filed an FBAR, so I’ve dug out all the old records.

1981

A. Schedule B – It contains Part III and the question about financial accounts in a foreign country.
(I believe the instructions for Sch. B referenced FBAR.)

B. FBAR, top instructions – “This form blah, blah blah. You are not required to file a report if the aggregate value of the accounts did not exceed $1,000.”
(That’s not a typing error, it says $1,000.)

C. FBAR Line 9 – “ If you had a financial interest in one or more….accounts which are required to be reported, and the total maximum value of the accounts exceeded $10,000 during the year,….”
(Note total maximum value of the accounts, not maximum aggregate value of the accounts, and $10,000 figure.)

D. Instructions on back of FBAR – Unfortunately, for 1981 I only have the top copy and not the back.

1982
A. Schedule B – It contains Part III and the question about financial accounts in a foreign country.

B. FBAR, top instructions – Same as 1981

C. FBAR Line 9 – Same as 1981

D. Instructions on back of FBAR – Unfortunately, top copy only..

1983

A. Schedule B – It contains Part III and the question about financial accounts in a foreign country.
(For 1983, includes directions to FBAR instructions and now asks for which countries the accounts are located in.)

B. FBAR, top instructions – “This form blah, blah blah. You are not required to file a report if the aggregate value of the accounts did not exceed $5,000.”
(That’s not a typing error, it says $5,000.)

C. FBAR Line 9 – Same as 1981.

D. Instructions on back of FBAR, Who must file – Each United States Person who has financial interest in or signature authority or other authority over bank, …..or other financial accounts in a foreign country which exceeds $5,000 in aggregate value at any time during the calendar year, must report that relationship each calendar year by filing TD F 90.22.1….”
(Note $5,000 figure.)

1984

A. Schedule B – Same as 1983

B. FBAR, top instructions – “This form blah, blah blah. You are not required to file a report if the aggregate value of the accounts did not exceed $5,000.”
(That’s not a typing error, it says $5,000.)

C. FBAR Line 9 – “ If you had a financial interest in one or more….accounts which are required to be reported, and the total maximum value of the accounts exceeded $10,000 during the year,….”
(Note total maximum value of the accounts, not maximum aggregate value of the accounts.)

D. Instructions on back of FBAR, Who must file – Same as 1983. ($5,000)

1985

A. Schedule B – Same as 1983.

B. FBAR, top instructions – “This form blah, blah blah. You are not required to file a report if the aggregate value of the accounts did not exceed $5,000.”
(That’s not a typing error, it says $5,000.)

C. FBAR Line 9 – Same as 1981.

D. Instructions on back of FBAR, Who must file – Unfortunately, only top copy.

1986

A. Schedule B – Same as 1983.

B. FBAR, top instructions – “This form blah, blah blah. You are not required to file a report if the aggregate value of the accounts did not exceed $10,000.”
(It now says $10,000.)

C. FBAR Line 9 – Same as 1981.

D. Instructions on back of FBAR, Who must file – Unfortunately, I only have the top copy.

From my limited files confusion reigns. For 1983, as for 1981, (C) FBAR Line 9 mentions “total maximum value of accounts exceeded $10,000″, but the instructions on the back of the FBAR states “which exceeds $5,000 in aggregate value at any time during the calendar year”. The (B) Top instructions don’t mention $10,000 until 1986.

I’m now off to find a life.

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