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IRS Issues FBAR Filing Relief, but Certain Filing Obligations Remain

Plan Filers invested in a foreign account, such as a foreign mutual find, should be preparing to file FBAR for 2009 by June 30, 2010 The Internal Revenue Service (IRS) has recently issued several pieces of guidance related to the filing of the Report of Foreign Bank and Financial Accounts, IRS Form...

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...

Sutherland Legal Alert: FinCEN Extends Due Date for Certain FBAR Filers

By Robb Chase and Amanda Pugh On February 14, 2012, the Department of Treasury's Financial Crimes Enforcement Network (FinCEN) issued Notice 2012-1, which extended the filing deadline for both the 2010 and 2011 Report of Foreign Bank and Financial Accounts (FBARs) to June 30, 2013, for certain...

Defendant Waives Attorney-Client Privilege by Asserting Reliance on FBAR Advice Defense

In United States v. Kerr, 2012 U.S. Dist. LEXIS 98836 (D AZ 2012) , a case with two U.S. taxpayers and their lawyer as defendants, the court held that the indicted U.S. taxpayers' claims of reliance constituted a waiver of their attorney-client privilege with respect to communications with their...