Apparently, around the middle of June, there was a teleconference on FBAR:
The idea was to "clarify" who had to file what on td f 90-22.1 by June 30. And by "file" they mean, "on our fucking desks" not "postmarked by".
Basically, some IRS folk, some lawyers, some CPAs. And one of the IRS guys (no, I _did not_ listen to the whole thing; I'm relying on secondary reporting. However, I did supply the link if you want to listen to that whole thing) supplied some "guidance" (wow, that's a lot of inappropriately used quotes) to the effect that offshore accounts included hedge funds. Needless to say, this surprised a lot of people who then attempted to get further "clarification" out of the IRS. On or around the 24th (getting suspiciously close to that by "file" we mean "on our fucking desks" deadline, right?), some "relief" was offered to people who didn't know they had to file (like, children whose names are on their parents accounts, say, accounts which happen to have >$10K in an offshore hedge fund). Those people (assuming they had reported and paid taxes on all their 2008 income) could send their form to a different address, _with their 2008 return_, a letter explaining why they hadn't filed it in a timely fashion and a few other odds and ends altho not, apparently, their firstborn.
At this point, it became apparent that, no, the IRS wasn't going to "clarify" this problem out of existence and everyone was going to have to fill out these forms (which aren't too bad if you have one fund, but could get ugly after a while, and they want odd things like the fund's mailing address and you know overseas mailing addresses). Yesterday's e-mail thus included a heads up to this effect. Which I received today, which is, of course, the filing deadline.
Hey, it's postmarked today. I'm going to assume they have enough trouble without wasting their time on me.