November16,2009.docVIP

November 16, 2009 The Honorable Michael F. Mundaca The Honorable Douglas H. Shulman Acting Assistant Secretary (Tax Policy) Commissioner Department of the Treasury Internal Revenue Service 1500 Pennsylvania Avenue, NW 1111 Constitution Avenue, NW Washington, DC 20220 Washington, DC 20224 Mr. William J. Wilkins Mr. Steven Musher Chief Counsel Associate Chief Counsel (International) Internal Revenue Service Internal Revenue Service 1111 Constitution Avenue, NW 1111 Constitution Avenue, NW Washington, DC 20224 Washington, DC 20224 Mr. Bill S. Bradley Mr. Jamal El-Hindi Chief Counsel Associate Director, Regulatory Policy FinCEN and Programs Division (FinCEN) Financial Crimes Enforcement Network Financial Crimes Enforcement Network Department of Treasury Department of Treasury P.O. Box 39 P.O. Box 39 Vienna, VA 22183 Vienna, VA 22183 Ms. Beth M. Elfrey Director, Fraud/Bank Secrecy Act Small Business/Self Employed Division Internal Revenue Service 1111 Constitution Avenue, NW Washington, DC 20224 Electronically sent to: Notice.Comments@ and regcomments@ RE: Comments on Filing Requirements for Reports of Foreign Bank and Financial Accounts (FBAR, Form TD F 90-22.1) Dear Messrs. Mundaca, Shulman, Wilkins, Musher, Bradley, and El-Hindi, and Ms. Elfrey: The American Institute of Certified Public Accountants (AICPA) is submitting comments on Notice 2009-62 regarding filing requirements for the Form TD F 90-22.1, Report of Foreign Bank and Financial Account (FBAR). The AICPA is the national professional organization of certified public accountants comprised of approximately 360,000 members. Our members advise clients of federal, state and international tax matters, and prepare income and other tax returns for millions of Americans. Our members provide services to individuals, not-for-profit organizations, small and medium-sized business, as well as America’s largest businesses. General Comments We thank the Internal Revenue