Delayed FBAR Filing For Signatory Authority

As reported in our prior client alerts, the Report of Foreign Bank and Financial Accounts, Form TD-F 90-22.1 ("FBAR") must be filed by a U.S. person that holds a financial interest in, or signature or other authority over, a foreign financial account if the aggregate value of all such U.S. person's foreign financial accounts exceeds $10,000 at any time during the year.

On June 16, 2011, the Internal Revenue Service released guidance (Notice 2011-54) stating 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. However, the deadline for reporting signature authority over, or a financial interest in, foreign financial accounts for the 2010 calendar year remains June 30, 2011.  For further coverage of recent FBAR guidance,