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US FBAR BSA E-Filing without Windows

Many US “persons”, including legal entities such as corporations, are obliged to report on their foreign (non-US) bank (and other financial) accounts via BSA E-Filing system. As of June 2014, this system only supports Windows. In practice, though, filing is possible from other operating systems, albeit not without issues. Here's a combination of software versions that sort of works:

  • A moderately non-ancient Linux distro with 32-bit userland and a typical set of X desktop software and libraries installed
  • Adobe Acrobat Reader 9.5.5 for Linux, AdbeRdr9.5.5-1_i486linux_enu.bin (still latest for Linux as of this writing)
  • Mozilla Firefox 17.0.1 (a later version will likely also work) for 32-bit x86

(For security, preferably use dedicated installs of these tools under a pseudo-user account or/and in a container or VM. Do not view untrusted PDFs and browse untrusted websites from this same account.)

Acrobat Reader must be configured as a plugin in Firefox. Simply having it launched on the PDF file or on the URL is not good enough, because the E-Filing system provides a PDF file with embedded JavaScript that (presumably) needs cookies from the logged in session. (With “acroread” invocation on a standalone PDF or on the URL, you won't be able to submit the filled out form - the JavaScript in it will keep saying you're not logged in.) To configure the plugin, symlink Acrobat Reader's nppdf.so (with full path to it) to the ~/.mozilla/plugins/ directory (or invoke /opt/Adobe/Reader9/Browser/install_browser_plugin, which might do this or something like it for you), then (re)start Firefox. Test that the plugin is working by visiting some trusted sample PDF file URL (outside of the E-Filing system for now, e.g. some IRS form on their website will do) - the PDF file contents should display inside the web browser window.

To actually fill out and file the form, log in to the E-Filing system and:

  1. Obtain your signing PIN via the “Manage PIN” link in the navigation on the left
  2. Proceed with “File FinCEN FBAR” (also in the navigation on the left), which opens a new browser window (it may also maximize that new window, ouch - but you can revert it to a sane size manually)
  3. Click “Open New Form” (or “Open Existing Form” if you've previously saved a partially filled out PDF form locally)
  4. Acrobat Reader 9.5.5 should complain about “a new format that this version of Acrobat does not support” once or twice (click “OK”), and the form should appear in the same browser window (sometimes the window just stays blank - if so, you may need to “Reload Tab” once or twice). Curiously (and luckily), BSA E-Filing system requirements list Acrobat Reader 9.5 as the oldest supported version, so 9.5.5 is “supported”.
  5. Fill out the form (BTW, the “Filing Name” is an arbitrary name you give to this filing for your own use/tracking), click Validate (it should complain about the lack of signature only), click “Sign with PIN” (and enter the PIN to the JavaScript pop-up that will appear)
  6. You cannot click Submit yet (it stays grayed out, apparently not recognizing yet that the form is already signed), and you should not click Save (if you do, Acrobat somehow saves the original PDF without your form inputs, and then it would not ask you to save changes when you exit it). Instead, close the browser window (yes, this is counter-intuitive). If you did sign the form, Acrobat (or a JavaScript?) will ask you if you want to save - click “Yes”. Then it will say it cannot save to the same filename, and offer to save to another - agree to that (and you may change the filename to any one you like). NB: if you did not fill out and sign the form, you are unlikely to be prompted to save whatever partial inputs you made.
  7. Proceed with “File FinCEN FBAR” again, and “Open Existing Form” with your filename from the previous step. This time, if you did sign the form in the previous step, you'll be able to click Submit - do it.
  8. You'll receive a pop-up giving you a “Tracking ID” (assigned by the system) and other info
  9. Also click “Track Status” in the navigation on the left to see your submission there in the “Accepted” state. The state should change to “Transmitted” after a while (check it on the next business day)
  10. Click “Logoff”
internal/biz/fbar.1404088620.txt · Last modified: 2014/06/30 02:37 by solar
 
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