Last Minute FBAR Extensions for “Signature Authority Only” Filers – Making Sense of the Announcements

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In the past week, two extensions for filing a Report of Foreign Bank and Financial Account (FBAR) were announced by the IRS and FinCEN for certain persons that are required to file FBARs solely as a result of their signature authority over a foreign financial account in which they have no financial interest. These extensions are in addition to the June 6, 2011, clarification of FinCEN Notice 2011-1 (May 31, 2011), which extended the FBAR filing due date for certain officers and employees of regulated entities or controlled entities of a regulated entity. The extensions announced for the FBAR filings originally due June 30, 2011, are summarized as follows:

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