New FBAR instructions
were added on June 11 2014 to emphasize this. The filing requirement
for minors is clarified on Page 6 by adding the following text:
Responsibility for Child’s FBAR
Generally, a child is responsible for filing his or her
own FBAR report. If a child cannot file his or her own FBAR for any
reason, such as age, the child’s parent, guardian, or other legally
responsible person must file it for the child.
Signing the child’s FBAR
If the child cannot sign his or her FBAR, a parent or guardian
must electronically sign the child’s FBAR. In item 45 Filer Title enter
“Parent/Guardian filing for child”
Also if certain monetary thresholds are met and the child is required to
file a tax return, the child may also be required to file Form 8938 –
Statement of Specified Foreign Financial Assets. This Form is
completely separate and distinct from the FBAR. It is not replaced by
the FBAR.
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