Discussion:T.D. F 90-22.1: Report of Foreign Bank and Financial Account.

From TaxAlmanac, A Free Online Resource for Tax Professionals
Note: You are using this website at your own risk, subject to our Disclaimer and Website Use and Contribution Terms.

From TaxAlmanac

Jump to: navigation, search

Discussion Forum Index --> Advanced Tax Questions --> T.D. F 90-22.1: Report of Foreign Bank and Financial Account.
Discussion Forum Index --> Tax Questions --> T.D. F 90-22.1: Report of Foreign Bank and Financial Account.

Stcpa (talk|edits) said:

11 September 2009

I hope this is the right section. I chose "Advanced" because not many people file this form. But the question is simply procedural.

I have a client that's required to file TD F 90-22 by the Extended deadline of Sept. 23rd. I only became aware of the obligation recently.

However, I need to provide an explanation as to why my client is filing late. I was wondering what "reasonable causes" are being used on the attachments. I was thinking something along the lines of "My client reported and paid tax on all his taxable income but only recently learned of his FBAR filing obligation." I do not know if this will suffice. Any advice is greatly appreciated.

Thanks in advance, stcpa

JAD (talk\|edits) said:	11 September 2009
Stcpa, did you see Notice 2009-62? Your deadline may be extended, and based upon the request for comments, I wonder if the final filing requirement will change.

Stcpa (talk\|edits) said:	11 September 2009
I did see the notice. Unfortunately, it does not apply to my client. Either case, I would still have to provide a "reasonable cause." I am wondering what the IRS has and has not accepted as a reasonable cause from real life examples.

Cody2826 (talk|edits) said:

11 September 2009

search "Reasonable Causes - good excuses" in the search box..you will find a previous thread.

This is what I recently used.

The taxpayer has reported all the income earned from this account on it’s previously filed 2007 Form 1065, but inadvertently did not complete the Form TD F 90-22.1 for the 2007 tax year. The taxpayer was not willfully neglecting or disregarding the tax laws. The taxpayer acted in a reasonable matter and filed the forms as soon as they determined they were required to file the forms. The recent guidance provided by the IRS has made it clear that the taxpayer did have a filing requirement for 2007. Procedures have been made to ensure that the filing deadline for future returns will not be missed.