The IRS has recently announced further guidance in the area of reporting non-U.S. bank and financial accounts. Most notable among the Proposed Regulations is an attempt to define a “financial account.” Additionally, the Notice announced that interests in hedge funds and private equity funds held in tax years 2009 and earlier do not have to be reported on the FBAR.

For more information, see Proskauer Client Alert, “The Foreign Bank and Financial Account Reporting Saga Continues: Further Relief for Prospective Filers,” March 5. 2010, available at http://www.proskauer.com/publications/client-alerts/the-foreign-bank-and-financial-account-reporting-saga-continues/