Gray Areas in the Interpretation of FBAR Rules: Evaluating IRS and U.S. Treasury Department Intention and Priorities

West LegalEdcenter


Edward L. Froelich

Edward L. Froelich

Speaking Engagement

U.S. Treasury Form TD F-90 22.1 "Report of Foreign Bank and Financial Accounts" (commonly known as the "FBAR") requires all U.S. persons, corporations or entities who had a financial interest in, or signature authority over, foreign financial accounts to file the FBAR if the aggregate value of the foreign financial accounts exceeded $10,000. A U.S person includes citizens and residents and domestic entities generally. The obligation to file this form is separate and independent from the obligation to file Form 8938 with one's income tax return. The two forms cover different accounts and assets, and filing of one does not discharge the obligation to file the other. Failure to file the FBAR can result in civil and criminal penalties, depending upon the nature of the failure. Many individuals, corporations and entities may have inadvertently or unintentionally failed to comply due to gray areas in the interpretation of FBAR rules. This webcast program will highlight:

  • Compliance requirements of U.S. Treasury Form TD F-90 22.1 "Report of Foreign Bank and Financial Accounts" (FBAR)
  • Agencies responsible for the administration of the FBAR – the IRS and the Financial Crimes Enforcement Network (FinCEN)
  • Application of the FBAR rules


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