US Tax: Revised foreign bank account reporting causes additional burdens for investment funds and advisors 

Jun 2009

Investment fund managers should be aware of major changes to the U.S. foreign bank account reporting rules that impact filings due on 30 June 2009.  Form TD F 90-22.1, "Report of Foreign Bank and Financial Accounts," has been revised and now requires significantly more information to be provided to the Internal Revenue Service ("IRS") regarding foreign financial accounts and owners of such accounts.
 
This reporting impacts U.S. individuals and entities that have ownership or control over foreign financial accounts.  Failure to file properly could bring significant monetary and criminal penalties.  Given the expanded scope of these reporting requirements, investment managers should begin to assess the impact of these new reporting rules on their filing obligations and determine the best course of action.
 
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