U.S. informational reporting requirements for U.S. persons who own shares of a foreign mutual fund  or  other “commingled fund” are remain unclear.  A U.S. person who invests in a foreign mutual fund through a foreign brokerage account is certainly required to report such ownership on their Form TD 90-22.1 (“FBAR”).  Reporting requirements for U.S.  persons who own shares of foreign holding corporations remain less clear cut.  New U.S. Treasury reporting guidance is forthcoming on this issue.  In the meantime, the Treasury has issued Notice 2009-62 (August, 2009), which permits those affected by the “commingled fund” reporting requirement to file an FBAR anytime before June 30, 2010 for tax year 2008 and earlier years.