Extension of FBAR Filing Deadline for Certain Offshore Investments
Client Memorandum

Created date

Informal comments by representatives of the IRS suggested for the first time on June 12, 2009 that investments in certain types of foreign hedge funds may constitute foreign financial accounts, for which a U.S. investor must file a Report of Foreign Bank and Financial Accounts (an “FBAR”).1 The IRS has not provided any written statement to that effect, however, or any guidance as to which types of funds would constitute foreign financial accounts for which filing is required.