Certain U.S. taxpayers who hold certain foreign equity awards or have deferred compensation plans issued by foreign entities now are required to file Form 8938, "Statement of Specified Foreign Financial Assets," with their federal income tax returns, beginning with their 2011 Form 1040. Absent an extension, Form 1040 is due on or before April 17, 2012. There are potentially significant penalties for failure to comply.

The filing covers interests in specified foreign financial assets. These include all financial accounts maintained by a foreign financial institution and any of the following assets held for investment: (i) stock or securities issued by non-U.S. persons, (ii) financial instruments or contracts issued by non-U.S. persons, including foreign pensions and deferred compensation plans, and (iii) any interest in a foreign entity. The specified foreign financial assets also include most foreign stock options, restricted stock units, and similar equity awards.