In comments sent to the IRS and published by Tax Notes, William Paul, Mary Plotkin, and Kerry Burke of Covington & Burling LLP, have requested guidance from the IRS and the Treasury regarding the Foreign Bank and Financial Accounts Report filing obligations of officers and employees of U.S. branches of foreign banks and officers and employees of broker-dealers that have been registered with the Securities and Exchange Commission.
See William Paul, Mary Plotkin, and Kerry Burke, "Tax Correspondence: Attorneys Seek Clarification on FBAR Reporting Obligations" 2009 TNT 140-16 (July 24, 2009)
Posted by Gary Robillard, Associate Editor, Wealth Strategies Journal.

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