For many other taxpayers the meter has been running since the end of June. Contrary to several reports, the IRS has not issued an across-the-board extension of the deadline for U.S. taxpayers to let it know about foreign bank accounts they owned in 2008 and in the six years prior.

An IRA missive released about 10 days ago, Notice 2009-62, spells out an extension on filing foreign bank-account reports (FBARs) from 23 September 2009 to 30 June 2010 exclusively for taxpayers "who only recently learned of their obligation to file an FBAR" -- but that's provided they get the proper documentation and proof to the IRS by the old deadline.

Beyond all recognition

Taxpayers who completed FBARs in prior years for the same accounts or whom the IRS believes to have known about their obligation to file FBARs (absent proof to the contrary) are still governed by the old deadline of 30 June 2009 -- yes: that's in the past -- and face penalties for filing late.

That is, if they had income from offshore accounts to report. If they didn't make money with their offshore investments and holdings, they have until 23 September 2009 to file FBARs or face stepped up fines and perhaps criminal prosecution.

"I have trouble with 29 years of experience and a masters degree in taxation keeping up with who needs to file what by when," Ron Cohen, a partner of the danville, Calif.-based business-service firm Greenstein Rogoff Olsenwrites in his International Tax blog.

The IRS says to stay tuned for more FBAR guidance. -FWR

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