IRS Issues Targeted Guidance, Treasury Proposes Rules on FBARs

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IRS unveils targeted guidance that practitioners say will provide significant relief for taxpayers required to file the Report of Foreign Bank Account, on the heels of comprehensive proposed rules on FBAR requirements issued by the Treasury's Financial Crimes Enforcement Network. The actions come as taxpayers and practitioners seek answers on a variety of questions regarding the FBAR, many revolving around what would be considered reportable foreign financial accounts and whether those with signature authority over certain accounts would be required to file the controversial form. IRS Announcement 2010-16 offers retroactive relief from FBAR filing for foreign entities and persons. Notice 2010-23 extends the FBAR filing deadline for some taxpayers with signature authority and who own commingled funds.