In the IRS 6/29/09 FAQ’s regarding FBAR filings, the IRS advised:
1. If a hedge fund is located in the U.S., with foreign operations, a financial interest in the U.S. hedge fund is not an interest in a foreign financial account for FBAR reporting purposes.
2. If a domestic partnership has a financial interest in a foreign financial account, then it may have to file a FBAR.
3. If a U.S. Person who is an officer, employee or partner of the partnership has a financial interest in, or signature or other authority over a foreign financial account then that person may have to file a FBAR.
4. If a person owns an interest in more than 50% of the profits of the partnership or more than 50% of the capital of the partnership, then that person has a financial interest (for FBAR reporting purposes) in the foreign financial accounts of the partnership and may have to file a FBAR.