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2013 efile of FBAR / FinCEN 114 - how will this work?

The latest release letter (Ver 34.0115) say:

New E-file Offerings available in Tax Year 2013:
• FBAR (Foreign Bank Account Report FinCEN 114):COMING IN APRIL

How exactly will this work? We are a Canadian firm who mainly service US citizens/taxpayers resident in Canada. We are not able to register with the IRS for e-file because none of the partners are US citizens or have SSN's.

The FinCEN 114 needs of course to be e-filed over the BSA system (which we are able to do), BUT this means entering the foreign account data twice - once into Lacerte for Form 8938/8891 purposes, and once more onto the PDF form that is submitted through BSA efile. It would be nice to only have to do this once.

Will we be able to file the FinCEN 114 through Lacerte to the BSA system without being registered with the IRS for efile??


  • You need to call support
    There is a link to contact us at the top - (888) 875-6701 for "interested in Lacerte"
  • Let us know what you find out.
  • The following Lacerte doc has further information:

    "How will it be e-filed, together with the main form or separately?

    Form 114 is a separate e-filing type from the federal return so it will be considered as a separate e-file. We will provide more information on how to e-file Form 114 later in the year."

    I will have to call support to see if our firm can e-file the Form 114 without having an IRS efile number.
  • Will we need to have all of our clients whose Form 114 that we will prepare and e-file for them sign Form 114a?  Will Form 114a be available through Lacerte or will we have to go to the BSA site to get it?  Also, on the Form 114a, it says:  "The Preparer/Filing Entity must be registered with FinCEN BSA E-FILE System."  So does that mean, we should first go to the BSA site and register as a "filer" and, if so, how will Lacerte know that we did register as a filer?  And if we do not have to register and Lacerte is the "Filer" then how do we fill out Part II of Form 114a, "Individual or Entity Authorized to File FBAR on behalf of Persons who have an obligation to file."?  

    (Ok, that's all the questions I have.... for now...  :-)
  • Good questions. I would like to know, too. I think we will know more in April.
  • <<<I will have to call support to see if our firm can e-file the Form 114 without having an IRS efile number.>>>

    I'm not a registered e-filer with the IRS...I file everything on paper (long story).  But I had no problem at all registering on the BSA site as a 3rd party preparer, preparing and filing a couple of 114s, and signing on behalf of my clients..  Got filing confirmations back by email, which I simply forwarded to the clients.  No big deal.  (Thank you, Susan!)
  • You're welcome.  But this process completely skipped ProSeries and/or Lacerte, didn't it? Lacerte is telling us it will have the FInCen 114 in April but they have been holding onto the details of how it will work.
  • Does it matter?  The 114 is not filed as part of the return, and you have to go to a different website to file it.  It's really not a "tax" form at all; it's only because of the old TDF90 form that we're even messing with it.  In light of how e-filing overall is going this year, I'd prefer to file it straight to the BSA from my office anyway.

    I'm looking at it as a separate $50 engagement.
  • Archie, many of our Canadian resident US citizen clients have to file both the 114 and Form 8938. So, being able to file the 114 through Lacerte ensures my staff don't have to enter the same account information twice. Moreover, it means I don't have to review it twice!
  • I get your point, I just don't have your issue...just a few local clients with foreign bank accounts or investments.  But, since the 114 goes through a completely different government agency, it wouldn't surprise me if the Intuit cure turns out to be worse than the disease.

    Since the due date is 6/30, you might consider the way a lot of us TX mom-and-pop shops handle the Texas Franchise Tax on businesses.  It's a quickie, it doesn't have a whole lot of integration with the US 1065 or 1120, and it's due on 5/15.  So I (and many others) do all our Franchise Tax returns at once, on a designated day after 4/15. Saves time, we only have to re-learn all the stupid TX rules once a year, and, again, it's a separate (though minor) engagement, which is billed separately.  Seems like the FBAR might also be a candidate for this type of treatment.
  • Our goal is to electronically file the 114 through Lacerte and not through the BSA site so I just need to know how we need to fill in the 114a that our clients will ultimately sign - are we (our firm) the registered filers of the form?  And if so, then I guess that means we need to go to the site and get registered - which I agree does look pretty easy.  I almost did it the other day but I don't want to if I don't have to. Lacerte the registered filer of the form?  I'm thinking they are not and we are so probably there will be something we can enter into our software so the BSA will know it's coming from us or something?  

    Filing through Lacerte would be great because we already have our client's information in there and we won't have to retype it.  So I'm hoping they will get it right.  

    They made e-filing the 5500s pretty easy even though the client has to jump through hoops to "sign" their return (not Lacerte's fault).  So I'm going to have faith just a little longer that Lacerte is going to get this all figured out...
  • I think they will, but haven't yet. At least they haven't shared yet. I would also prefer to do this through Lacerte but have already registered at BSA.

This was posted on Lacerte's "Top Solutions"

FinCEN Form 114-Foreign Bank Account Report (FBAR) (Previously Form TDF 90-22.1)Description

Information on FinCEN Form 114 and Frequently Asked Questions.

Detailed Information

FinCEN Form 114- Report of Foreign Bank and Financial Accounts (FBAR) is used to report financial interest in or signature authority over foreign financial accounts and replaces Form TDF 90-22.1.

The FinCEN Form 114 must be electronically filed and received on or before June 30th.


  1. When will Form 114 be available in Lacerte?

    FinCEN Form 114 will be available in the Lacerte Tax Program in April 2014.

  2. Will Lacerte support E-filing of FinCEN Form 114?

    Yes. The current plan is to support Form 114 electronically in all modules in the 2013 Lacerte tax program.

  3. How will it be e-filed, together with the main form or separately?

    Form 114 is a separate e-filing type from the federal return so it will be considered as a separate e-file. We will provide more information on how to e-file Form 114 later in the year.

  4. I need to e-file Form 114 before April 2014, how can I do this?

    You can manually create and e-file Form 114 on the FinCEN website. See BSA E-filing System and BSA Steps for more information.

For additional information visit the FinCEN website. For further assistance when using the BSA E-filing website you can contact the BSA E-Filing Help Desk at 1-866-346-9478.


    >>>I will have to call support to see if our firm can e-file the Form 114 without having an IRS efile number<<<

    I've got the same problem.  I'm in the US, but I have an exemption from e-filing.  Is that going to cost my clients with foreign accounts $10,000 each?  If so, I need to build it into my fee structure.

    By the way, AND THIS IS SERIOUS!  Make sure all your clients know that a 1040 extension does NOT extend the time for filing the 114.  As far as I can tell, there is no provision at all for extending those beyond 6/30.
    • Chuck-you and/or your clients can efile the FInCen 114 at the BSA website. A firm can register there to submit returns on behalf of its clients.
    • Ahh, thanks.  That will allow me to stay in the Luddite Club.
    • I try to be helpful.
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