On August 31, 2009, the Department of the Treasury and the IRS published Notice 2009-62, which, in part, extended the filing deadline for persons with no financial interest in a foreign financial account but with signature authority over that account for the 2008 or earlier calendar years.
During 2010, Notice 2010-23, published by the Department of the Treasury and the IRS, further extended relief to persons whose filing deadline was properly deferred by Notice 2009-62 and provided a new filing deadline of June 30, 2011, to report signature authority over, but no financial interest in, foreign financial accounts for calendar year 2009 or earlier calendar years.
The extensions were provided to allow the Treasury Department time to develop comprehensive FBAR guidance.
The IRS has now provided additional administrative relief to those taxpayers who are otherwise required to file FBARs by 6/30/2011. Persons with signature authority over, but no financial interest in, foreign financial accounts for which an FBAR would have been due by 6/30/2011 will now have until 11/1/2011 to file for 2009 and prior calendar years.
Please note that the current year FBAR filing due date is still 6/30/2011 even for signature only filers.
Please give us a call if you have any questions regarding this issue.