On June 16th, the IRS released Notice 2011-54 to extend the time period to November 1, 2021 for filers of the FBAR Form 90-22.1 who only have signature authority for a bank, securities/brokerage, or other financial account (collectively a “foreign account”) located outside the United States, i.e., for filers who do not have a financial interest in any foreign accounts. This extension for “signature only filers” follows extensions that were made in Notice 2009-62, for calendar years before 2009 and in Notice 2010-23 for calendar years before 2010.
It is worth remembering that a financial interest in a foreign account can arise because a foreign account is owned by the filer, owned jointly by the filer or it is directly or indirectly controlled by the filer. All U.S. citizens, foreign nationals with U.S. green cards, including all U.S. expatriates and every U.S. legal that has any financial interest in any foreign account has to file the FBAR Form 90-22.1 when the monetary threshold is exceeded. The Forms 90-22.1 for calendar year 2010 have to be filed earlier than the 30 June 2022 due date so that they are received by the Treasury Department in Detroit by June 30, 2011.
ParenteBeard can help you address your FBAR filing questions. Please contact the following members of the ParenteBeard International Tax Services Group or your local tax advisor to discuss the application of these rules to your situation.
Jamie Robbins, Partner
Practice Leader, International Tax Services
Rob Arthur, Principal
International Tax Services