• IRS And FinCEN Revise FBAR Filing Requirements
  • March 23, 2010 | Authors: Dustin M. Covello; L. Wayne Pressgrove; John C. Taylor
  • Law Firms: King & Spalding LLP - Atlanta Office ; King & Spalding LLP - London Office
  • The Internal Revenue Service (IRS) issued Notice 2010-23 and Announcement 2010-16 (collectively, the “IRS Guidance”) regarding Form TD F 90-22.1, Report of Foreign Bank And Financial Accounts (the FBAR) on February 26, 2010. Notice 2010-23 provides administrative relief to taxpayers who would otherwise be required to file the FBAR by June 30, 2010. Announcement 2010-16 suspends the FBAR filing requirement for persons who are not U.S. citizens, U.S. residents, or domestic entities. The Financial Crimes Enforcement Network (FinCEN), a bureau of the Department of the Treasury, contemporaneously issued proposed regulations regarding FBAR filing requirements (the “Proposed Regulations”). This alert discusses the IRS Guidance and the Proposed Regulations.