News 24 Jun. 2021
Curtis successfully defends foreign states' procedural privileges in the UK Supreme Court
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News 23 Jun. 2021
Ibrahim Elsadig joins Curtis as Partner in Dubai
Client Alert 24 Feb. 2022
EU, UK, Japan and Australia Impose Sanctions on Russia
News 09 Aug. 2021
Curtis, Mallet-Prevost, Colt & Mosle enters into association with Chevalier Law in Singapore.
News 06 May. 2022
Curtis Advises Terna Group on the Sale of its Latin America Power Transmission Assets to CDPQ
Publications 05 May. 2022
Marie-Claire Argac, Simon Batifort, and Cyprien Mathié share highlights from “Affaires d’Etats: Practical Considerations When Defending States in International Arbitration” on Kluwer Arbitration Blog
Event 26 Apr. 2022
Claudia Frutos-Peterson Speaks at CAI Costa Rica’s 13th Congress of International Arbitration
News 21 Apr. 2022
SCOTUS Upholds U.S. Colonialism under the U.S. Constitution
Client Alert 23 Mar. 2022
The Dubai International Arbitration Centre (DIAC) has launched the DIAC Arbitration Rules 2022
Event 22 Nov. 2021
Partner Antonia Birt spoke at ADGMAC and AIAC Webinar Series: Webinar 5 - Disputes in Fintech and Complex Technology in MESEA
News 19 May. 2022
Eliot Lauer’s and Juan Perla’s Tenth Circuit Arguments Featured on Audio Arguendo Podcast
News 16 May. 2022
Curtis Files SCOTUS Amicus Brief for Ohio Justice & Policy Center in Prisoners’ Rights Case
Client Alert 21 Apr. 2022
New Laws Targeting Assets of Russian Oligarchs: The U.S. Announces Task Force KleptoCapture and the Kleptocracy Asset Recovery Rewards Program
Client Alert 19 Apr. 2022
U.S. President Biden Expands Export Controls Imposed on Russia and Belarus
Client Alert 24 Jun. 2021
Update on Virtual Notarization (Executive Order 202.7) During the COVID-19 (Coronavirus) Pandemic (Updated: June 24, 2021) — U.S. Insight
Update on Virtual Witnessing (New York Executive Order 202.14) During The COVID-19 (Coronavirus) Pandemic (Updated: June 24, 2021) — U.S. Insight
Publications August 10, 2009
On August 7, 2009, the IRS issued Notice 2009-62 to extend the deadline of filing Form TD F 90-22.1 ('FBAR') in two limited situations. The extension applies to U.S. persons who have signature authority over, but no financial interest in, foreign financial accounts, and to U.S. persons with respect to investment in foreign 'commingled funds' such as hedge funds. Under the Notice, these signatories and investors have until June 30, 2010 to file the FBAR for 2008 and prior years. A U.S. person not eligible for the extension under the Notice generally must file the FBAR by June 30, but if such person was unaware of the filing obligations until recently, the extended September 23, 2009 deadline announced by the IRS earlier this year may apply.
The IRS has recently indicated that 'commingled funds' that are treated as 'financial accounts' include mutual funds, hedge funds, and even private equity funds. However, there is no official guidance as to whether and under what circumstances an equity interest in a foreign entity should be treated as a 'financial account' subject to FBAR reporting. The Treasury Department now intends to issue regulations to provide clarification. Such regulations may address when an interest in a foreign entity should be subject to FBAR reporting, whether the principles of 'passive foreign investment company' should apply, and whether duplicative filing should be exempt. Similarly, such regulations may also address whether a signatory should be exempt from an FBAR obligation when the owner of the account files the FBAR, and whether officers and employees with only signature authority should not be required to file duplicative FBAR forms. Interested persons can submit comments and suggestions to the IRS and the Treasury Department by October 6, 2009.
To ensure compliance with requirements imposed by the IRS, we inform you that, unless explicitly provided otherwise, any U.S. federal tax advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein.
Marco A. Blanco
Partner
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