FBAR Filing Deadline for Extensions for Certain Individuals With Signature Authority

McDermott Will & Emery
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The Financial Crimes Enforcement Network and the Internal Revenue Service recently issued three notices, FinCEN Notices 2011-1 and 2011-2 and IRS Notice 2011-54, granting an extension of the filing deadline for the Report of Foreign Bank and Financial Accounts (FBAR), IRS Form TD-F 90-22.1 to different groups of individuals with signature or other authority over certain foreign financial accounts for various filing years.

The Financial Crimes Enforcement Network (FinCEN), a division of the U.S. Treasury Department, and the Internal Revenue Service (IRS), recently issued three notices, FinCEN Notices 2011-1 and 2011-2 and IRS Notice 2011-54. Each notice granted an extension of the filing deadline for the Report of Foreign Bank and Financial Accounts (FBAR), IRS Form TD-F 90-22.1 to different groups of individuals with signature or other authority over certain foreign financial accounts for various filing years. Refer to our previous On the Subject for a discussion of whether an individual has signature or other authority over a foreign financial account.While the extensions provide welcome relief, some June 30, 2011 filing obligations still remain.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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