AICPA FBAR and FATCA Advocacy Efforts 

The AICPA has and continues to advocate on behalf of taxpayers and tax preparers with respect to the reporting of foreign bank and financial accounts (FBAR) and foreign account tax compliance (FATCA).  This page pulls together all AICPA public comment letters and testimony on these subjects.  In addition, we have had numerous meetings and calls with various government agencies associated with issues and concerns in these areas.

Comment Letters and Testimony

AICPA 06.27.2011 Comment Letter requesting confirmation of the treatment of persons with signature or other authority over, but no financial interest in, a foreign bank or financial account for FBARs relating to pre-2010 calendar years

AICPA 05.31.2011 Comment Letter requesting to eliminate or reduce filing of FBAR for 2009 and prior years for those with signature authority over, but no financial interest in, a foreign bank or financial account

AICPA 11.19.2010 Comment Letter on foreign trust concerns associated with Amendment to the Bank Secrecy Act Regulations - reports of foreign financial accounts (FBAR) - in response to the 02.26.2010 Notice of Proposed Rulemaking under Title 31 (RIN-1506-AB08) by the Financial Crimes Enforcement Network (FinCEN)

AICPA 04.30.2010 Comment Letter on Amendment to the Bank Secrecy Act Regulations - reports of foreign financial accounts (FBAR) - in response to the 02.26.2010 Notice of Proposed Rulemaking under Title 31 (RIN-1506-AB08) by the Financial Crimes Enforcement Network (FinCEN).

AICPA 11.16.2009 Comment Letter on Foreign Bank Account Reporting - in response to Notice 2009-62.

AICPA Statement entered into testimony of 11.05.2009 Hearing by House Ways and Means Subcommittee on Select Revenue Measures regarding Foreign Bank Account Reporting and Tax Compliance.