FBAR – Will you be Little Miss Perfect?

Following a change in US law, the 2016 FBAR is technically due to be filed by 18 April 2017. Because that is the date printed on the FBAR form; many Little Miss Perfect's we know are rushing to file by that date.

The filing date for an FBAR for 2016 can, however, be automatically extended to 16 October 2017. There is no requirement to request this extra time, as the filing date is extended automatically to 16 October 2017 without any extension form being required. 

Great news for many!

Following a change in US law, the 2016 FBAR is technically due to be filed by 18 April 2017. Because that is the date printed on the FBAR form; many Little Miss Perfect's we know are rushing to file by that date.

The filing date for an FBAR for 2016 can, however, be automatically extended to 15 October 2017. There is no requirement to request this extra time, as the filing date is extended automatically to 15 October 2017 without any extension form being required. 

Great news for many!

Even better news, the 15th is a Sunday so the automatic extension is to 16 October 2017. 
https://www.irs.gov/uac/rda-2017-01-11-2016-fincen-form-114

Alan - if only wishes came true. The 15th is set out in statute. When I asked FinCEN they said "no can do", because they can't change what the law says. The weekend rule used by the IRS does not apply to FinCEN. Stick with midnight Central Standard Time on the 15th and we'll be safe!

Yes, unlike tax returns paper reports by mail are not allowed, so day of the week is not a reason for delay since the servers are available 7 days a week.

So the IRS website that reports 16 October 2017 as the extended due date must be incorrect.  Someone should tell the Treasury.
And also H&R Block:
https://www.hrblock.com/expat-tax-preparation/articles/fbar-fatca-filing-requirements.html

Even KPMG reports an extended due date of 16 October 2017:

"But wait, there’s more to the new FBAR due date. The 2015 legislation also prescribes the granting of a six-month extension. Although the process for U.S. taxpayers to obtain an extension of time to file their income tax return is to affirmatively make such a request, FinCEN announced that FBAR filers in 2017 will automatically receive a six-month extension of time to file their FBAR. Thus, no action by an FBAR filer is required to receive the extension of time to file. This effectively moves the FBAR due date to October 15. For 2016 FBARs, FinCEN also announced that the due date will shift to October 16, 2017, since October 15 falls on a Sunday (again, an announcement by FinCEN was necessary because the Saturday, Sunday, or legal holiday rule in section 7503 does not apply to FBARs). Accordingly, U.S. individuals and entities have until October 16, 2017, to timely file their calendar year 2016 FBAR." [Bold added]
https://home.kpmg.com/content/dam/kpmg/us/pdf/2017/02/tnf-wnit2-feb20-2017.pdf

We're splitting hairs, but I suspect the 16th is the real due date.  Let us know what FinCEN says about it.  (I filed my FBAR a couple weeks ago.)