The Harvard Law School Forum on Corporate Governance https://corpgov.law.harvard.edu The leading online blog in the fields of corporate governance and financial regulation. Sun, 31 May 2026 11:30:19 +0000 en-US hourly 1 https://wordpress.org/?v=6.5.8 https://corpgov.law.harvard.edu/wp-content/uploads/2024/02/cropped-photography-4-e1706898544564-1-32x32.png Treasury Clarifies FBAR Regulations for Private Investment Funds – The Harvard Law School Forum on Corporate Governance https://corpgov.law.harvard.edu 32 32 Treasury Clarifies FBAR Regulations for Private Investment Funds https://corpgov.law.harvard.edu/2011/05/08/treasury-clarifies-fbar-regulations-for-private-investment-funds/?utm_source=rss&utm_medium=rss&utm_campaign=treasury-clarifies-fbar-regulations-for-private-investment-funds https://corpgov.law.harvard.edu/2011/05/08/treasury-clarifies-fbar-regulations-for-private-investment-funds/#comments Sun, 08 May 2011 13:13:03 +0000 http://blogs.law.harvard.edu/corpgov/?p=17342?d=20150120092859EST Posted by Noam Noked, co-editor, HLS Forum on Corporate Governance and Financial Regulation, on Sunday, May 8, 2011
Editor's Note:

The following post comes to us from Betty Santangelo, Philippe Benedict, Shlomo C. Twerski and William I. Friedman of Schulte Roth & Zabel, and is based on a Schulte Roth & Zabel client alert.

On March 28, 2011, the Final Regulations, issued by the Financial Crimes Enforcement Network of the U.S. Department of the Treasury (“Treasury”) relating to the filing of Reports of Foreign Bank and Financial Accounts (“FBAR”) became effective. Notably, the Final Regulations do not require ownership interests in, or signing or other authority over, private investment funds, such as hedge funds and private equity funds, to be reported on FBARs, although Treasury will continue to study the issue.

The Final Regulations apply to FBARs required to be filed by June 30, 2011 with respect to foreign financial accounts maintained in the calendar year 2010, and for all subsequent years. United States persons who deferred FBAR filings for prior reporting years in accordance with guidance issued by Treasury, [1] may apply the provisions of the Final Regulations in determining their FBAR filing requirements for any deferred reports due June 30, 2011.

A revised FBAR form (Form TD-F-90-22.1) and General Instructions, which should be used for the June 30, 2011 filing deadline, were also recently released.

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