FURTHER UPDATE: IRS Extends FBAR Filing Deadline in Limited Circumstances


We recently alerted clients to the looming FBAR filing deadline of June 30, 2009. The IRS has now provided a limited extension of the deadline until September 23, 2009 FOR SOME—BUT NOT ALL—TAXPAYERS.

To qualify for the September 23 extension, a taxpayer must have: (i) reported and paid tax on all of their 2008 taxable income; (ii) only recently learned of their FBAR filing obligation; and (iii) insufficient time to gather the necessary information to complete the FBAR. The IRS will not impose a penalty for the failure to file the FBAR in this situation.

If a taxpayer qualifies for the extension, the taxpayer must send a copy of the delinquent FBAR, together with a copy of the 2008 tax return (unless such return is due after September 23, 2009) and a letter explaining the reason the FBAR is late, by September 23, 2009 to the following address (note this is a different address than the address applicable to the June 30 deadline):

Internal Revenue Service
11501 Roosevelt Blvd.
South Bldg., Room 2002
Philadelphia, PA 19154
Attn: Charlie Judge, Offshore Unit, DP S-611

If a taxpayer does not qualify for the extension, the June 30 deadline remains in effect. In this case, the IRS MUST RECEIVE the FBAR by June 30, 2009 at the following address:

U.S. Department of the Treasury
Post Office Box 32621
Detroit, MI 48232-0621

For more information, please contact:

Kenneth K. Bezozo

Taylor H. Wilson



Vicki L. Martin-Odette



You may also view this alert in the PDF below.

In order to comply with certain U.S. Treasury regulations, we are informing you that any U.S. federal tax advice that may be contained in this document is not intended or written to be used, and cannot be used, by any person for the purpose of (i) avoiding any tax penalties that may be imposed by the Internal Revenue Service or any other U.S. federal taxing authority or agency or (ii) promoting, marketing, or recommending to another party any transaction or matter addressed herein.

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