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IRS Advises on FBAR Filing Requirement for Insurance Company

MAR. 10, 2022

ECC 202225008

DATED MAR. 10, 2022
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Citations: ECC 202225008

[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

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