Additional FBAR Relief for Certain Foreign Financial Account Signatories

Additional FBAR Relief for Certain Foreign Financial Account Signatories

by Keith J. Blum, Partner - Boies, Schiller & Flexner LLP

On June 16, 2011, the IRS, in Notice 2011-54, further extended the deadline from June 30, 2011, to November 1, 2011, for the filing of the Report of Foreign Bank and Financial Accounts (FBAR) for persons with no financial interest in a foreign financial account but with signatory or other authority over such accounts for calendar years 2009 or earlier.  The deadline continues to be June 30, 2011 for calendar year 2010.

Notice 2011-54 benefits investment funds and managers that have authority over foreign financial accounts in which such investments fund or managers have no legal or beneficial ownership interest... 

The IRS, together with the Financial Crimes Enforcement Network (FinCEN), are granting this additional relief because they have been informed that persons with signature authority over foreign financial accounts in which they have no financial interest are having difficulty in collecting the required information to permit a complete and accurate FBAR filing with respect to calendar years prior 2010.

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Importantly, the notice does not affect the requirement to provide information or file FBARs in connection with the IRS's 2009 Offshore Voluntary Disclosure Program or the Offshore Voluntary Disclosure Initiative... 

View Keith Blum's insights in their entirety on the Private Equity, Venture Capital and Hedge Fund Taxation site.

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