U.S. citizens and residents (including individuals, corporations, partnerships, trusts and estates) who have a financial interest in or signature or other authority over any "financial accounts" in a foreign country are required to make a separate filing if the aggregate value of these accounts exceeded $10,000 at any time during 2008.  Filing requirements also apply to those with direct or indirect control over a foreign or domestic entity with foreign financial accounts, even if the taxpayer does not have foreign financial accounts of its own.  Foreign "financial accounts" include a wide variety of items, such as but not limited to:

• Bank Accounts    
  
• Securities   
  
• Mutual Funds
• Credit Cards    
  
• Retirement Plans   
  
• Life Insurance

Because both persons with a financial interest and persons with signature authority are required to submit filings, a single account can require multiple filings.  For example, a corporate-owned foreign account would require filings by the corporation and by the individual corporate officers with signature authority.  Unfortunately, the rules do not permit one person to submit a filing on behalf of others.
 
These filings must be made by June 30, and the time for filing is not extended by a tax return extension.   There are severe civil and criminal penalties for non-compliance of these filing requirements.  Even an inadvertent failure or incomplete filing can result in a $10,000 civil penalty, and the IRS has announced that it intends to enforce these penalties.
 
We are able to assist you in the preparation of these foreign account filings if you request.  These services are beyond the scope of normal tax return preparation and will result in an additional fee.  If you would like us to prepare these filings, or if you have questions concerning your filing obligations, you should contact us as soon as possible and provide us with all requested information.