Tax Correspondence to IRS: Ruling Requested on Reporting Requirements for FBAR

J. Barclay Collins of WilmerHale LLP, responding to Announcement 2009-51, has requested an administrative ruling from the IRS guidance on the interpretation of the application of the Bank Secrecy Act for foreign financial account reporting on Form TD F 90-22.1 ("FBAR").  The correspondence requests that the IRS rule that employees are not required to report on an FBAR their interest in shares under an employee stock ownership plan and held in offshore custody arrangements established by the employer. 

See also Firm Seeks Guidance on Reporting Requirements on FBAR Form," 2010 TNT 47-22, March 11, 2010.

Posted by Neil I. Rumbak, Associate Editor, Wealth Strategies Journal.