Now is the time to notify officers and employees of their 2012 FBAR-related reporting obligations

| January 2012

Overview

Officers and employees who are U.S. citizens or residents may have to file a Form TD F 90.22-1, Report of Foreign Bank and Financial Accounts (FBAR), by June 30, 2012 to report a financial interest in, or signature or other authority over, foreign financial accounts. In addition, individual taxpayers must affirmatively state on their U.S. federal income tax returns whether they have a financial interest in, or signature or other authority over, foreign financial accounts and whether they are required to report these accounts on an FBAR. As a result, companies may need to provide officers and employees who are U.S. citizens or residents and who have signature or other authority over company-owned foreign financial accounts with information about the accounts now to allow these individuals to meet their reporting obligation.

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