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New Guidance on FBAR Filing Requirements

On February 26, 2010, the Internal Revenue Service (IRS) issued official guidance (the IRS Guidance) regarding the Report of Foreign Bank and Financial Accounts (commonly referred to as FBAR), applicable for 2009 and prior years, clarifying which U.S. persons are required to file the FBAR form and which accounts are required to be reported, and further extending until June 30, 2011 the FBAR filing deadline for certain persons with signature authority over a foreign financial account. On the same date, the Treasury Departments Financial Crimes Enforcement Network issued proposed rules (the Proposed FBAR Rules) that, if finalized, would further clarify these issues.

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