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Results: 1-10 of 16

Uncertainties regarding applicability of FBAR filings due June 30, 2009

  • Fried Frank Harris Shriver & Jacobson LLP
  • -
  • USA
  • -
  • June 17 2009

Each United States person who has a financial interest in, or signature or other authority over, any foreign financial accounts must file Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts (the “FBAR”), with the US Treasury Department if the aggregate value of these financial accounts exceeds $10,000 at any time during the applicable calendar year

FBARs not currently required for interests in foreign hedge funds or private equity funds

  • Lowenstein Sandler PC
  • -
  • USA
  • -
  • March 2 2010

The Treasury Department has provided some welcome relief concerning Foreign Bank Account Report (FBAR) filing requirements, although many key issues remain unresolved

Proposed regulations exempt taxpayers from FBAR reporting for interests in offshore private equity and hedge funds until further guidance is issued

  • Proskauer Rose LLP
  • -
  • USA
  • -
  • March 3 2010

On February 26, 2010, the Treasury Department published long-awaited, revised proposed regulations clarifying which taxpayers will be required to file the Report of Foreign Bank and Financial Accounts, Form TD F 90-22

IRS offers relief for filing 2008 FBARs

  • Fried Frank Harris Shriver & Jacobson LLP
  • -
  • USA
  • -
  • June 24 2009

We previously advised about significant uncertainties that exist with respect to the recently revised Form TD F 90-22

Investments in private investment funds: subject to FBAR reporting by June 30, 2009 or not?

  • Venable LLP
  • -
  • USA
  • -
  • June 26 2009

For more than 30 years, US law has required all US persons who have a financial interest in, or signatory or other authority over, an offshore financial account where the amount exceeds $10,000 to file the US Treasury Department Form 90-22.1 (“FBAR”) with its office in Detroit, Michigan

Investors face expanded FBAR filing obligation, deadline extended

  • Choate Hall & Stewart LLP
  • -
  • USA
  • -
  • June 30 2009

US investors holding interests in offshore private equity, venture capital and other investment funds may now be required to disclose such interests on the Report of Foreign Bank and Financial Accounts

Foreign Account Tax Compliance Act of 2009 would require additional disclosure by offshore private funds and their advisors

  • Katten Muchin Rosenman LLP
  • -
  • USA
  • -
  • November 6 2009

Representative Charles Rangel and Senators Max Baucus, Richard Neal and John Kerry introduced the Foreign Account Tax Compliance Act of 2009 (Bill) in Congress, which would require U.S. withholding agents to withhold tax on payments of income from U.S. financial assets to “foreign financial institutions” unless such foreign financial institutions comply with certain disclosure obligations; require additional disclosure by U.S. persons with interests in foreign entities, accounts, and passive foreign investment companies; and require disclosure by any advisor who receives more than $100,000 in compensation for aiding a U.S. person in establishing a foreign entity or investing in foreign financial assets, or face penalties

IRS offers additional relief for filing 2008 (and earlier) FBARs

  • Fried Frank Harris Shriver & Jacobson LLP
  • -
  • USA
  • -
  • August 7 2009

We previously advised about significant uncertainties that exist with respect to Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts and related instructions (the “FBAR”) (most notably, with regard to whether US persons who hold interests in offshore hedge funds or offshore private equity funds are required to file FBARs with respect to such interests

FBAR filing not required for interests in offshore private equity and hedge funds for calendar years 2009 and earlier

  • Paul, Weiss, Rifkind, Wharton & Garrison LLP
  • -
  • USA
  • -
  • March 1 2010

Last Thursday and Friday the Internal Revenue Service (the “IRS”) and the Financial Crimes Enforcement Network (“FinCEN”) of the Department of the Treasury issued current guidance and Proposed Regulations covering a number of important issues with respect to the requirement to file Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts (“FBAR”

New developments affect reporting obligations for U.S. interests in non-U.S. private investment funds

  • Schulte Roth & Zabel LLP
  • -
  • USA
  • -
  • March 23 2010

In late February, the Treasury Department (“Treasury”) issued Notice 2010-23 (“Relief Notice”) and Announcement 2010-16 (the “Announcement”), providing additional guidance relating to the filing of Reports of Foreign Bank and Financial Accounts (Form TD F 90-22.1) (“FBAR”) for all years through 2009

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