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This page contains a single entry by Associate Editor published on March 12, 2010 4:40 PM.

Tax Correspondence to IRS: Clarify that Foreign Investments by U.S. Qualified Retirement Plans Not Financial Accounts for FBAR Purposes was the previous entry in this blog.

Tax Correspondence to IRS: Exception from FBAR Requirement Needed for U.S. Persons Who Live and Work Abroad is the next entry in this blog.

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Tax Correspondence to Treasury and IRS: Clarify that Passive Investors in Offshore Private Real Estate Investment Funds Not Subject to FBAR Filing Requirement

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Gail Chapman Haynes of the Pension Real Estate Association, has issued a correspondence to the IRS and Treasury.  The correspondence requests the following from the IRS and Treasury: "(A) The following specific guidance:
(1) that public and private tax exempt organizations be exempt from the filing requirements of the FBAR rules; and their directors, officers and employees likewise be exempt from the filing requirements of the FBAR rules with respect to any signature or other authority over financial accounts owned by or on behalf of such tax exempt organizations;
(2) that foreign real estate investment funds be excluded from the definition of a "foreign financial account" for FBAR purposes; and
(3) in the event item (1) above is not granted, then directors, officers and employees of a tax exempt organization be exempt from the FBAR filing requirements that may arise solely due to signature or other authority over financial accounts owned by or on behalf of such organization, to the extent that such accounts are reported by the organization under the FBAR rules and such director, officer or employee has no personal finance interests in such accounts; and

(B) an extension of time to comply with the FBAR filing requirements, until such time as definitive guidance is published."


See also Pension Real Estate Group Seeks Clarification on FBAR Reporting Requirement, 2010 TNT 48-15, March 12, 2010.

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


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