UPDATE: Filing Deadline for Report of Foreign Bank and Financial Accounts

Our June 17, 2009 Alert, Reporting of Foreign Bank and Financial Accounts, was a reminder of the June 30, 2009, deadline for filing the Treasury Department Form 90-22.1 ("FBAR"). On June 24, 2009,the IRS posted an update to its Frequently Asked Questions regarding its voluntary disclosure program for unreported foreign financial accounts, (the "FAQs"). The FAQ now provides that taxpayers have until September 23, 2009, to file their 2008 FBAR as a "delinquent FBAR report" without a penalty for failure to file if they: a) reported and paid tax on all 2008 taxable income, b) only recently learned of their FBAR filing obligations, and c) had insufficient time to gather the necessary information to complete the FBAR.

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