December 2016 JD Supra

Foreign Financial Institutions (FFIs) and host country tax authorities have provided IRS with a second round of information reports on financial accounts held by US Taxpayers. This exchange of information is automated and standardized among Government Tax Authorities and IRS, also directly by FFIs in Non-IGA and IGA 2 Countries. IRS has information from over 200,000 FFIs about financial accounts held by US Taxpayers, or by foreign entities in which US Taxpayers hold a substantial ownership interest. So what could be next for US Taxpayers that haven’t disclosed and properly reported their foreign financial accounts?