Several weeks ago, we reported on the extension of the filing
deadline for the Report of Foreign Bank and Financial Accounts
("FBAR"). These reports are required for individuals and
entities which hold either a financial interest in or signatory
authority over a foreign financial account. The types of reportable
accounts had been expanded through recently revised filing
instructions and informal comments by IRS representatives. The IRS
then extended the filing deadline until September 23, 2009 for
taxpayers who reported and paid tax on all of their income from
foreign accounts but who only recently learned of their FBAR filing
obligation.
On August 7, the IRS issued Notice 2009-62, which provides
additional relief by further extending the deadline for filing 2008
and earlier FBAR until June 30, 2010 for (i) persons with signature
authority over, but no financial interest in, a foreign financial
account and (ii) persons with a financial interest in, or
