Key Takeaways The IRS has dramatically expanded international enforcement capabilities through FATCA , automatic information exchange, and data analytics Penalty stacking can result in combined penalties exceeding 100% of unreported foreign account balances The statute of limitations for FBAR violations is 6 years; for substantial omissions of foreign income, also 6 years; for fraud, unlimited Three main paths to resolution exist: Streamlined Procedures , Voluntary Disclosure, and quiet disclosure (not recommended) Defense strategies include challenging willfulness, asserting reasonable cause, and arguing proportionality Contact Neil Jesani Tax Resolution immediately if you have unreported foreign income or the IRS has contacted you IRS International Enforcement: A Growing Priority The IRS has made international tax enforcement one of its highest priorities, dedicating substantial resources to identifying and pursuing US taxpayers who fail to report foreign income and financial accounts. This enforcement effort has intensified dramatically since the 2009 UBS case, which exposed widespread offshore tax evasion by US taxpayers and led to fundamental changes in international tax transparency. The IRS's international enforcement infrastructure now includes: FATCA automatic reporting: Foreign financial institutions in over 100 countries report US account holder information directly to the IRS through FATCA and intergovernmental agreements Common Reporting Standard (CRS): While the US does not participate in CRS directly, information exchanged under CRS between other countries can reach the IRS through treaty-based information exchange Data analytics: The IRS uses sophisticated algorithms to cross-reference FBAR filings, FATCA reports, tax returns, and information from foreign governments to identify discrepancies John Doe summonses: The IRS continues to issue summonses to foreign financial institutions to obtain US account holder identities IRS investigation Division: IRS-CI dedicates a significant portion of its resources to international tax fraud cases Whistleblower program: Incentivizes reporting of offshore tax evasion with awards up to 30% of amounts collected Types of...