The June 30, 2012, deadline for filing a Report of Foreign Bank
And Financial Accounts ("FBAR") with the Department of
the Treasury is rapidly approaching. (Form TD-F 90-22.1). The
government established the FBAR reporting requirement following the
terrorist attacks of September 11, 2001, as a way to combat
financing of terrorism through foreign accounts. The government has
vigorously enforced FBAR rules and regulations and instituted
substantial penalties. However, individuals and entities who failed
to file required FBAR forms for past reporting years have a new
opportunity to reduce applicable penalties.
Under the current regulations, United States citizens, resident
aliens of the United States, and entities formed under the laws of
the United States or any State must file an FBAR on or before June
30 of each year identifying each "bank, securities, or other
financial account in a foreign country" held during the
previous year, in which the taxpayer has "a
