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December 22, 2023

FinCEN continues to extend certain signature authority reporting (FBAR, Form 114)

In FIN-2023-NTC5 (the Notice), released December 20, 2023, the Financial Crimes Enforcement Network (FinCEN) further extended the filing deadline for certain individuals who previously qualified for an extension of time to file the Report of Foreign Bank and Financial Accounts (FBAR) regarding signature authority under Notice 2022- 1 and previous guidance.

The Notice pertains only to individuals who were initially granted extensions of time to report signature authority under FinCEN Notices 2011-1 and 2011-2 (most recently extended by FinCEN Notice 2022-1). Under the Notice, individuals have until April 15, 2025, to file deferred FBARs, subject to any potential further extension. Any persons not covered by the Notice for 2023 will have until April 15, 2024 — automatically extended six months to October 15, 2024 — to file their FBARs for the 2023 calendar year.

Tax Alert 2022-1877 provides additional information related to this extension, the history of the notices, additional guidance considerations and factors affecting whether to defer the 2023 filing.

In no case is an extension (beyond the automatic six-month extension) available for financial interest filing obligations.


Contact Information
For additional information concerning this Alert, please contact:
International Tax and Transaction Services
   • Lauren Lovelace (
   • Matthew S. Blum (
   • Kunal Pawa (
Information Reporting & Withholding Services
   • Jonathan Jackel (
   • Saul Tilmann (

Published by NTD’s Tax Technical Knowledge Services group; Andrea Ben-Yosef, legal editor