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ARTICLE · 02 JUNE 2010

FBAR: Deadline Approaches, Issues Remain for Employee Plans

Mayer Brown
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The US Internal Revenue Service and the Financial Crimes Enforcement Network ("FinCen") of the Department of Treasury issued guidance in February 2010 with respect to the "Report of Foreign Bank and Financial Accounts."

United StatesTax
Maureen Gorman
Maureen Gorman
Debra Hoffman
Debra Hoffman
Ryan Liebl
Ryan Liebl
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Originally published May 27, 2010

Keywords: Financial Crimes Enforcement Network, FinCen, FBAR, employee benefit plan, financial accounts, Notice 2010-23, Announcement 2010-16, United States person, Bank Secrecy Act

The US Internal Revenue Service and the Financial Crimes Enforcement Network ("FinCen") of the Department of Treasury issued guidance in February 2010 with respect to the "Report of Foreign Bank and Financial Accounts." The guidance was provided in the form of proposed regulations under the Bank Secrecy Act (the "BSA"), IRS Notice 2010-23 and IRS Announcement 2010-16. These materials provide important relief and guidance with respect to FBAR filings. This Update briefly describes the guidance contained in those materials and reviews issues associated with their application to employee benefit plan-related FBAR filings.

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