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FBAR Problems And Proposed SolutionsFBAR Problems And Proposed Solutions

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

Elyse G. Kirschner, Partner

November 1, 2009

11 Min Read
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Elyse G. Kirschner

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 sort out the filing requirements and submit their FBAR forms. As a result, the number of FBAR filers has skyrocketed, despite the significant effort and cost associated with filing current and past FBAR reports. Clearly, further guid...

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About the Author

Elyse G. Kirschner

Partner, McDermott, Will & Emery LLP