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International Tax Bulletin (June 2011)

Foreign Accounts—Extended Due Date for
Certain FBARs for 2009 and Earlier




By Brian Wainwright, and William E. Bonano, tax partners in the Palo Alto and San Francisco offices, respectively, of Pillsbury Winthrop Shaw Pittman LLP.

For more information on foreign account reporting, please see our May 2011 International Tax Bulletin, Foreign Accounts—Recent IRS Enforcement Activity and June 30th Reporting Deadline, also available in a printed, pdf version.


On June 17, 2011, the Internal Revenue Service released Notice 2011-54. Under this Notice, persons having signature authority over, but no financial interest in, a foreign financial account in 2009 or earlier calendar years for which the reporting deadline was extended by Notice 2009-62 or Notice 2010-23 will now have until November 1, 2011, to file FBARs (Forms TD F 90-22.1) with respect to those accounts.

However, the deadline for reporting signature authority over, or a financial interest in, foreign financial accounts for the 2010 calendar year remains June 30, 2011.


This material is not intended to constitute a complete analysis of all tax considerations. Internal Revenue Service regulations generally provide that, for the purpose of avoiding United States federal tax penalties, a taxpayer may rely only on formal written opinions meeting specific regulatory requirements. This material does not meet those requirements. Accordingly, this material was not intended or written to be used, and a taxpayer cannot use it, for the purpose of avoiding United States federal or other tax penalties or of promoting, marketing or recommending to another party any tax-related matters.


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