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From The Opalesque Team:

U.S. law firm Katten Muchin Rosenman LLP alerted clients that every US investor in an offshore hedge fund should file a Report of Foreign Bank and Financial Accounts (FBAR). The reports, which have a deadline of June 30, 2009 reflect the calendar year 2008. US investors who have not filed FBAR's in prior years but that have reported and paid tax on all taxable income have a deadline of September 23, 2009 for bringing their reporting up to date without penalty.

The firm, which participated in a teleconference with IRS personnel said that the government agency's position is that "an offshore hedge fund is a 'foreign financial account' for FBAR purposes".

The team at Katten has informed its clients of the following recommendations that should be followed until the IRS issues further guidance.

- Every US investor, including US tax-exempt entities, in an offshore hedge fund (this includes both stand-alone offshore hedge funds and the offshore feeder in master/feeder hedge fund structure - US feeder funds that invest in offshore master funds, and any US investor that owns more than 50% of the US feeder - Any direct US investor in an offshore master fund Investment managers that have a financial interest (for example through their carry) in any offshore hedge funds (whether stand-alone feeder or master)... Corporate website:......................

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