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FBAR Rules for Employee Benefit Plans

By Marcia S. Wagner
September 30, 2010

On Feb. 26, 2010, the Financial Crimes Enforcement Network (“FinCEN”) issued proposed regulations regarding foreign bank account reporting on Form TD F 90-22.1 (the “FBAR”). Employee benefit plans and those with authority over their investment activities may be required, like other investors, to file an FBAR if plan investments involve foreign banks or securities accounts. The FBAR for calendar year 2009 had to have been filed with the IRS no later than June 30, 2010.

General Reporting Requirements

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