Alert

Recommended Alerts

Sign Up For Alerts

Large IRAs and High-Income Retirement Savers Targeted by Amendment to Budget Reconciliation Bill

Last week, Richard Neal (D-Mass), chairman of the House Committee on Ways and Means, unveiled an amendment to help fund the $3.5 trillion budget reconciliation legislation that is currently under consideration in Congress. The Neal amendment would make dramatic changes to the rules governing retirement plans for certain high-income taxpayers by imposing new asset limitations and prohibitions. It would also require distributions and IRA contribution limitations for certain individuals with retirement savings over $10 million, require distributions of Roth balances in excess of $20 million and end the practice of so-called “back-door” Roth conversions. These changes aim to effectively prohibit mega IRAs, which were the subject of extensive press reports earlier this year following ProPublica’s revelation of multiple large IRAs, including Peter Thiel’s $5 billion mega-Roth IRA.

Read More

IRS Extends Certain FBAR Filing Deadlines to June 30, 2010


Time to Read: 1 minutes Practices: Tax, Hedge Funds Industries: Educational Institutions

Printer-Friendly Version

With limited exceptions, each U.S. person with either a financial interest in or signature (or comparable) authority over one or more foreign financial accounts is required to report that relationship annually to the Internal Revenue Service (IRS) on U.S. Treasury Form TD F 90-22.1, "Report of Foreign Bank and Financial Accounts" (FBAR). Recently, there has been significant controversy related to the FBAR filing requirements for (i) persons with signature authority over, but no financial interest in, a foreign financial account, and (ii) persons with a financial interest in, or signature authority over, a foreign commingled fund. Previously, the IRS provided an extension of FBAR filing deadlines in certain circumstances to September 23, 2009. (See also our June 19 alert relating to the FBAR.)

IRS Notice 2009-62, released earlier today, extends until June 30, 2010 the FBAR filing deadlines for the 2008 and earlier calendar years for (i) persons with signature authority over, but no financial interest in, a foreign financial account, and (ii) persons with a financial interest in, or signature authority over, a foreign commingled fund. Notice 2009-62 also indicates that the U.S. Department of the Treasury intends to issue regulations clarifying the FBAR filing requirements as applicable to persons in both of the foregoing categories, and solicits comments related thereto.

We are continuing to review Notice 2009-62 and related authority in order to provide detailed guidance for particular client situations. If you would like to discuss Notice 2009-62 or other issues concerning FBAR filings, please contact your usual Ropes & Gray lawyer.

Circular 230 Disclosure: To ensure compliance with Treasury Department regulations, we inform you that any U.S. tax advice contained in this communication (including any attachments) was not intended or written to be used, and cannot be used, for the purpose of avoiding U.S. tax-related penalties or promoting, marketing or recommending to another party any tax-related matters addressed herein.

Printer-Friendly Version

Cookie Settings