¹ The author publishes a free email newsletter (The Jacobs Report; see http://finance.groups.yahoo.com/group/jacobsreport/) on international tax law and related foreign asset-protection subjects and has received numerous questions from subscribers about the requirements for filing TD F 90-22.1. This article is an edited compilation of those questions and the author’s interpretation of the instructions and applicable law.

² See also the Privacy Act of 1974 (P.L. 93-579). This article is condensed from a larger report available to AICPA Tax Division members at www.cpa2biz.com/ResourceCenters/Tax/International/default.htm. Numerous Internet sources are provided in that version, including copies of pertinent parts of the U.S. Code.

³ See, e.g., Schedule N, Foreign Operations of U.S. Corporations, of Form 1120, U.S. Corporation Income Tax Return; Form 1065, U.S. Return of Partnership Income; Form 1041, U.S. Income Tax Return for Estates and Trusts; and Form 990-T, Exempt Organization Business Income Tax Return.

⁴ See note 1, supra. These responses are not intended to imply that the IRS or Treasury concurs. Although assistance was provided by some members of the International Tax TRP and the Form 5471 Task Force, the opinions expressed herein are the author’s alone.

⁵ See note 1, supra.

⁶ See www.e-gold.com/unsecure/aboutus.html.