On June 16, 2011, the Internal Revenue Service issued IRS Notice 2011-54, granting additional relief to persons with signature or other authority over, but no financial interest in, a foreign financial account held during calendar year 2009 or earlier calendar years.
Previous, IRS Notices 2009-62 and 2010-23 already extended this deadline until June 30, 2010: “Persons with signature authority over, but no financial interest in, a foreign financial account for which an FBAR would otherwise have been due on June 30, 2010, will now have until June 30, 2011, to report those foreign financial accounts.” (IRS Notice 2010-23).
Notice 2011-54 further states that:
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 with respect to those accounts. The deadline for reporting signature authority over, or a financial interest in, foreign financial accounts for the 2010 calendar year remains June 30, 2011.
Thus, IRS Notice 2011-54 extends the FBAR filing deadline from June 30, 2011 until November 1, 2011 for all persons with signature authority over, but no financial interest in, a foreign financial account in 2009 or earlier calendar years.
Be careful, though – the deadline for the 2010 FBAR remains June 30, 2011.
Also, note that the relief granted by FinCEN Notices 2011-1 and 2011-2 is not affected by IRS Notice 2011-54.
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If you believe that you may be subject to FBAR requirements, contact Sherayzen Law Office as soon as possible. Our experienced international tax firm will guide you through the complex maze of FBAR reporting requirements, including any voluntary disclosure issues.
Remember, it does not matter whether you are located in another state or outside of the United States – we can help!