A lot of ink and press coverage has been given to recent developments between the US Department of Justice and Swiss financial institutions. There are many foreign nations who host financial or investment accounts for US taxpayers. Property and controlling interests in offshore companies exist around the world, and the US is aggressively pursuing all of it. Failure to electronically file this year’s FBAR (Fin Cen Form 114) can result in a penalty of up to $10,000 – and that is if the IRS deems that the omission wasn’t “willful”. The IRS has never been more aggressive at collecting offshore tax revenues, and they have done an extensive job of communicating the responsibilities of US expatriates, US citizens with accounts or property overseas, and foreign nationals who live and work in the United States. Up to this point, the IRS has needed the assistance of the taxpayer to identify offshore funds. This has substantially and permanently changed in 2014. Thanks to FATCA, the IRS and the US Justice Department are pursuing overseas banks and credit companies with criminal allegations. It’s a big stick. So big that many Swiss institutions voluntarily agreed to provide the IRS information after all these years. My message to you is simple: it’s not just the Swiss. If you have investment accounts or property interests offshore, the time to “come into compliance” with the IRS is now. July 1 may be too late.
