U.S. persons are required to file FBAR Form TD F 90-22.1 annually if they have a financial interest in or signature authority over foreign financial accounts totaling more than $10,000.
Recently, IRS and the Treasury Department's Financial Crimes Enforcement Network (FinCEN) announced an amendment to the 2010 FBAR filing deadline. Specific individuals possessing only signature authority over foreign bank accounts who are required to file a yearly Report of Foreign Bank and Financial Accounts (FBAR) have a one-year extension beyond the upcoming June 30, 2011, filing deadline.
In order to foster more accurate compliance of FBAR filings Notice 2011-1 extends the FBAR deadline until June 30, 2012, for the following U.S. Persons:
... An employee or officer of a controlled person of a covered entity who has signature or other authority over and no financial interest in a foreign financial account of the entity or another controlled person of the entity.
... 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% owned, directly or indirectly, by the entity (a controlled person).
All other U.S. persons required to file an FBAR this year are still required to meet the June 30, 2011, filing date. Unlike with federal income tax returns, extensions of time to file are not available for FBAR filing reports.
The attorneys of Williams Coulson have successfully advised several clients on FBAR matters, including matters related to the 2011 Initiative. Please do not hesitate to contact Edward P. Wojnaroski, Jr., Stephen J. Pieklik or Brandon P. Smith to discuss any FBAR issues that you may have.