The IRS announced that a small subset of financial professionals will be granted a one-year extension to file the Foreign Bank Account Report (FBAR). Generally, any U.S. person with $10,000 in a foreign bank account in any year must file an FBAR by June 30 of the next year. This requirement applies to anyone with a beneficial interest OR signature authority on an account. The new exception will extend the filing deadline for 2010 by one year, to June 30, 2012, for:
- An employee or officer of a covered entity who has signature or other authority over and no financial interest in a foreign financial account of another entity more than 50 percent owned, directly or indirectly, by the entity (a “controlled person”).
- An employee of another controlled person (see the notice for details).
This notice was issued “to facilitate more accurate compliance of FBAR filings in the wake of recent finalization of regulations.”
This development does not affect most ordinary people, but is still worth knowing for professionals in the field.
Attorney Morris N. Robinson expects soon to publish an article about “The Coming Crackdown” of IRS enforcement against delinquents who did not report their foreign accounts and did not participate in the Voluntary Disclosure Program. See http://www.masstaxlawyers.com/masstax-alert-irs-the-first-step-in-a-massive-crackdown/
IR-2011-57, which is also FinCEN Notice 2011-1: http://www.irs.gov/newsroom/article/0,,id=239881,00.html