Any U. S. person who has a financial interest in, or signature authority over, a foreign bank account that has a value in excess of $10,000 at any time during a calendar year must file Form TD F 90-22.1 with Treasury on or before June 30 of the following year.  (See 31 CFR § 103.24.)   A "U.S. person," for purposes of these rules, includes U.S. citizens and residents as well as U. S. legal entities.  It is important to note that this reporting obligation is imposed not only on the college or university that has the "financial interest in" the foreign bank account, but also on the institution's employees who have "signature authority over" the account.

In rare instances a University employee may have signature authority over a foreign account associated with an activity sponsored by a unit of the University.  Study abroad programs would be one example.   Even though the employee cannot use the account for the employee’s own benefit, the employee may be required to file Department of the Treasury Form TD F 90-22.1 and notify the IRS as noted below.

In addition, a person who is required to report his or her signature authority over a foreign bank account to the Treasury Department on Form TD F 90-22.1 is required to report such signature authority to the IRS.  And the vehicle is the individual's personal income tax return, specifically, Lines 7a and 7b of Schedule B, Form 1040.  Line 7a asks the taxpayer to respond to the following question:

At any time during the tax year (for which the return is being filed), did you have an interest in or signature authority over a financial account in a foreign country, such as a bank account, securities account, or other financial account?

If the answer to this question is Yes, Line 7b asks the taxpayer to enter the name of the country where the bank account is located.

There may be penalties for not filing the required forms.   Instructions and forms can be found at http://www.irs.gov/pub/irs-pdf/p4261.pdf.