20 pages. Excerpt: We write to respond to the Treasury's request for comments regarding FBAR and the accompanying instructions. As noted in our July 29, 2009 letter and discussed in more detail below, the policy goals of FBAR ? to detect and prevent taxpayers from hiding assets offshore toavoid income taxes or launder money ? are not advanced by requiring U.S persons to file an FBAR with respect to 'foreign financial accounts' held by or for the benefit of Plans. Nevertheless, Treasury may expect at least a 40 percent increase in annual FBAR filings (nearly 75,000 additional filings) from Plans qualified under Code section 401(a), which would test IRS's already limited resources to indentify violators. Thus, we respectfully make the following recommendations[.]

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