With respect to the 2008 calendar year, each United States person who had a financial interest in, or signature or other authority over, any foreign financial account generally must file Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts (the “FBAR”), by June 30, 2009. The FBAR and related instructions were revised for filings in respect of the 2008 calendar year, and two aspects of these revisions have given rise to recent uncertainty and are of particular interest to the asset m