Forgot a Foreign CD on Your FBAR? Check the Tax Return Too

You are preparing this year's records when you realize that a foreign CD was missing last year. Perhaps you filed the FBAR yourself while a tax preparer handled the return. Perhaps the preparer filed “another foreign-account form,” but you do not know which one.

The next step is to reconstruct the filing record. Adding the CD to this year's paperwork does not explain what happened in the earlier year.

Make a three-part filing inventory

Create a folder for the affected year and request the actual submitted documents. A draft, an organizer, and a completed filing are different records.

Use the CD account-number checklist if a certificate and a savings account share a customer number. Resolve that ambiguity before preparing the replacement account list.

Identify the “other form” by looking at the return

Do not infer the form from a description such as “the one with my bank balances.” Ask for its number and a copy. It may be Form 8938, but the filing record should establish that.

The IRS explains that Form 8938 and FBAR have separate filing requirements. Form 8938 goes with the tax return; FBAR goes to FinCEN. Filing one does not replace the other. See the IRS comparison.

A useful message to the preparer is:

“Please send my complete filed return and all foreign-asset attachments for the year. Please confirm whether you also filed an FBAR, and provide its acknowledgment if so. I found a foreign time deposit that may have been missing from the records I supplied. Please confirm whether its interest was included and what you need to assess a correction.”

Keep the response with the year's records. Assign responsibility for each next step so two people do not unknowingly submit overlapping corrections.

Separate an amendment from a never-filed report

If a report was filed but is incomplete, FinCEN's amendment instructions call for a complete new FBAR marked as amended, with the prior BSA identifier. Follow the current instructions for a missing identifier. The correction is not just a standalone entry for the omitted CD. See FinCEN's amendment instructions.

If no FBAR was filed, the issue is different. The IRS's late-FBAR guidance addresses delinquent reports and directs filers using a compliance option to follow that option's instructions.

A prior-year omission does not by itself establish eligibility for Streamlined or any particular penalty treatment. Missing income, multiple years, government contact, or uncertainty about conduct changes the review. Bring notices and prior correspondence to the adviser before selecting a procedure.

Check the interest separately

Find the annual interest statement or reconstruct payments from the institution's records. Then ask where those amounts appear on the filed return. Do not assume that reporting an account balance also reported its income.

Foreign investment income can be reportable even without a U.S. Form 1099. The timing of CD interest can also require review of the deposit terms. IRS Publication 550 is the starting source for that analysis.

Keep three statuses in your organizer: confirmed, missing, and needs explanation. “I think my preparer included it” belongs in the third category until you can reconcile the documents.

Prepare a correction handoff

Give the adviser a short summary of when you discovered the omission, which years may be affected, what was originally provided to the preparer, and which filings you have located. Preserve the original documents and correspondence.

Ask for a written scope that identifies the filings to be reviewed, who will prepare any corrections, and what is outside the engagement. Avoid reducing the decision to how quickly a form can be resubmitted.

Start an FBAR catch-up consultation if an earlier report appears missing or incomplete. If the uncertainty is still about what accounts you own, begin with the foreign accounts consultation. Both start with your facts; neither link establishes a correction procedure or promises a penalty result.