IRS Advises on FBAR Filing Requirement for Insurance Company
ECC 202225008
- Institutional AuthorsInternal Revenue Service
- Code Sections
- Subject Area/Tax Topics
- Jurisdictions
- Tax Analysts Document Number2022-20519
- Tax Analysts Electronic Citation2022 TNTI 122-192022 TNTG 122-252022 TNTF 122-31
[Third Party Communication: * * *
Date of Communication: Month DD, YYYY]
UILC: 9999.99-01
Release Date: 6/24/2022
ID: CCA_2022031013015912
From: * * *
Sent: Thursday, March 10, 2022 1:01:59 PM
To: * * *
Cc: * * *
Bcc:
Subject: RE: FBAR question
Hi * * *,
It turns out that corporations do have a FBAR filing requirement. Entities created, organized, or formed under the laws of the United States have an FBAR filing requirement. See 31 CFR 1010.350(b); IRM 4.26.16.2.1.
You've indicated that the corporation under exam was organized in the * * *, but that it made an election under § 953(d) to be treated as a domestic life insurance company. So, the question of whether the corporation has a FBAR filing requirement appears to turn on the effect of that election.
* * *
Thanks.
Taylor H. Huse
Attorney
CC:PA:02
Direct: (202) 317-5428
- Institutional AuthorsInternal Revenue Service
- Code Sections
- Subject Area/Tax Topics
- Jurisdictions
- Tax Analysts Document Number2022-20519
- Tax Analysts Electronic Citation2022 TNTI 122-192022 TNTG 122-252022 TNTF 122-31