Key Takeaways FATCA requires foreign financial institutions in 100+ countries to report American account holders directly to the IRS FBAR penalties for willful violations can reach $100,000 or 50% of account balance per violation — whichever is greater Voluntary disclosure and the Streamlined Filing Compliance procedures offer paths to compliance without IRS enforcement action The IRS has collected over $12 billion from offshore compliance initiatives since 2009 IRS enforcement action for offshore tax evasion has resulted in sentences of up to 10 years in prison The End of Offshore Secrecy The era of using foreign bank accounts to hide income from the IRS is over. Beginning with the landmark UBS case in 2009 — where the Swiss banking giant agreed to turn over the names of thousands of American account holders — the IRS has systematically dismantled the infrastructure of offshore tax evasion. The Foreign Account Tax Compliance Act (FATCA), enacted in 2010 and implemented globally through intergovernmental agreements (IGAs), requires foreign financial institutions to identify and report their American account holders to the IRS. Today, over 300,000 foreign financial institutions in more than 100 countries report account information to the IRS automatically. Reporting Requirements You May Be Missing FBAR (FinCEN Form 114) If you have a financial interest in or signature authority over one or more foreign financial accounts with an aggregate value exceeding $10,000 at any time during the calendar year, you must file an FBAR by April 15 (with automatic extension to October 15). "Foreign financial accounts" include: Bank accounts (checking, savings, certificates of deposit) Securities and brokerage accounts Mutual funds and pooled investment vehicles Insurance policies with cash value Pension and retirement accounts Accounts held through foreign trusts or entities FATCA (Form 8938) FATCA requires U.S. taxpayers to report specified foreign financial assets on Form 8938,...