The Internal Revenue Service's recent efforts to enforce the reporting of foreign bank accounts has created a lot of confusion for many people. This is particularly true for beneficiaries of trusts, as well as for holders of interests in foreign hedge funds and private equity funds. In fact, during the past four months, the IRS has offered taxpayers several different extensions of time to file the “Report of Foreign Bank and Financial Accounts” (FBAR) in an attempt to encourage taxpayers to ...

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