Sutherland Alert: FinCEN Extends FBAR Filing Deadline for Certain Officers and Employees – Does This Portend Changes?

by Carol Tello, Dwane Dupree, and Robb Chase

On May 31, 2011, in FinCEN Notice 2011-1, the Department of Treasury's Financial Crimes Enforcement Network (FinCEN) extended the 2010 Report of Foreign Bank and Financial Accounts (FBAR) filing deadline from June 30, 2011, to June 30, 2012, for certain officers and employees with signature authority but no financial interest in a foreign financial account. The officers and employees eligible for the extended effective date generally are persons that may have qualified for an exception to individual FBAR filing under the FBAR rules in effect prior to the finalization of the regulations in February of this year, but that do not qualify for an exception under the regulations as finalized and therefore are required to file individual FBARs reporting their signature authority. The Notice also appears to provide relief to officers and employees of U.S. subsidiaries of foreign corporations the stock of which is listed on a U.S. exchange. Those persons generally were not eligible for an exemption even before the regulations were finalized. Click here for a copy of Sutherland's March 4 Legal Alert.

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