On June 17, 2011, the Financial Crimes Enforcement Network
("FinCEN") issued Notice 2011-2 ("Notice"),
which extends to June 30, 2012 the filing deadline for certain
individuals to file their Reports of Foreign Bank and Financial
Accounts ("FBARs"). Under the Notice, which is available
here, officers and
employees of investment advisors registered with the Securities and
Exchange Commission with signature or other authority over, but no
financial interest in, foreign financial accounts of entities which
are not registered investment companies (that is, are not
investment companies registered under the Investment Company Act of
1940) are granted a one-year extension to June 30, 2012 to file
FBARs. (Existing guidance exempts officers and employees of
registered investment advisors from filing FBARs to report
signature authority over foreign financial accounts that are owned
or maintained by registered investment companies.)
This extension was granted in light of questions about processing
issues in filing FBARs for these individuals by the June 30, 2011
compliance date. The extension applies to FBARs for calendar year
2010 and FBARs for 2009 and earlier years for which the filing
deadline was properly deferred under IRS Notice 2009-62 or IRS
Notice 2010-23, discussed
here and
here.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
