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16 April 2020
On the evening of 9 April 2020, the Inland Revenue Service (IRS) issued Notice 2020-23 postponing additional tax deadlines to 15 July 2020. The notice clarifies that the extended deadline relief includes not just the filing of specified income tax forms, but also all schedules, returns and other forms that are filed as attachments to income tax forms or are required to be filed by the due date of a specified income tax form. Relevant to offshore structures and their advisers, the 15 July 2020 deadline now applies to the following forms, among others:
The IRS notice does not address the report of foreign bank and financial accounts (FBAR), Financial Crimes Enforcement Network (FinCEN) Form 114, which is not a tax form. Under the Bank Secrecy Act (BSA), US persons are required to file an FBAR to report certain foreign financial accounts, such as bank accounts, brokerage accounts and mutual funds. The FBAR is an annual report filed through the FinCEN BSA e-filing system. If they fail to meet the regular FBAR 15 April due date, US persons are allowed an automatic extension to 15 October. It is not necessary to request an extension to file the FBAR by 15 October.
For further information on this topic please contact Jennie Cherry at Kozusko Harris Duncan's New York office by telephone (+1 212 980 0010) or email (firstname.lastname@example.org). Please note that the author is unable to provide legal advice to non-clients. The Kozusko Harris Duncan website can be accessed at www.kozlaw.com.
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