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Form 3916 Question


Daft Doctor

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Hi, quick question on form 3916. The form basically asks for declaration of any foreign accounts 'ouvert, clos ou utilisé' during the year. We have a few UK accounts remaining, but most of them are just dormant, either with a nil balance or £1, and have had no transactions through them for a few years. Do these have to be declared, as they haven't been 'utilisé' during 2016? Any insight welcomed, advice will be taken at face value.
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I have always taken "ouvert" to mean "open" rather than "opened", so declare any existing accounts every year.

If declaring on line they reappear automatically each year anyway, so it's not really much effort to declare them, and it possibly keeps a few people busy, so they don't have time to dig deeper into my affairs[:)].

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Thanks, the doubt in my mind is because the official notes for completing form 2042 this year state:

'Si en 2016, vous (ou un des membres du foyer) avez ouvert, utilisé ou clôturé des comptes bancaires à l’étranger, joignez à votre déclaration des revenus la déclaration no 3916 ou une note sur papier libre reprenant les mentions de cet imprimé et cochez la case 8UU'

That to me is clearer in its meaning than form 3916, as it translates as 'If.........you have opened, closed or used foreign bank accounts.......' This seems in keeping with excluding dormant accounts when taken in conjunction with the bit on form 3916 which says 'Les comptes à déclarer sont ceux ouverts hors de France...............recevant habituellement en depôt des valeurs mobilières, titres ou espèces..... so translated roughly as 'those accounts open outside France..................habitually receiving deposits of stocks and shares, securities and cash'

That said, given the potential fines, I think you're probably right to declare all if there's a doubt.......
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