Just a reminder that FBARs must be electronically filed with Fincen no later than 6/14/14. There is no extension available for FBARs. Even if all the information is not available for a required filer, one should file by the deadline and amend later. Failure to file on time penalties can be severe.
Information I just learned yesterday about resident aliens:
Individuals who are resident aliens of the U.S. are treated no differently then citizens. You are a resident alien if you are a lawful permanent resident (have a green card) or if you pass the substantial presence test. Here is what I just learned: The tax treaty provision that deals with tie-breakers for the definition of residency are not applicable for FBARs. This means that when you come upon an individual who under the substantial presence test is a resident of the US and is also a resident of the other contracting state for whatever reason, an FBAR must be filed (assuming the requirements for having to file an FBAR are met) even if under the tie-breaking clause in the treaty, the individual is not treated as a US resident for treaty purposes.