Is filing Forn 1040 required?

[Kram BergGold]

My client is abroad and in 2009 did not have enough income to be required to file, however she has more than $10,000 in a foreign bank account. Does she have to file a 1040 with a Schedule B and then a TD F 90-22.1 or just the TD F 90.221?

[appelman]

The FBAR reporting requirement is separate.

If filing of a tax return is not otherwise required, I would just do the TD F 90.221.

See:

http://www.irs.gov/businesses/small/article/0,,id=148849,00.html