Today, the IRS announced an extension until November 1, 2011 for taxpayers who did not file TD F 90-22.1 (FBARs) forms in prior years. For those taxpayers who only had signatory authority over a foreign account and did not own the account in 2009 or prior years, additional time has been granted to gather the necessary information to file the old FBARs.
This is a helpful development for many taxpayers who are attempting to gather information from financial institutions where the there was no ownership.
The IRS on two prior occasions extended the deadline while it considered its position. See Notice 2011-54 for the current reporting obligations.