Important New Development Regarding Reporting of Foreign Bank and Financial Accounts: What Corporations and Individuals Need to Know

The Internal Revenue Service (IRS) has made enforcement of foreign bank and financial account reporting obligations a top priority, both with respect to corporate and individual taxpayers. As discussed in detail below, the penalties for any compliance failure are particularly punitive, and the hurdle for the application of such penalties is low. With tax season approaching, the next few weeks are an excellent time to review compliance with these obligations because these reporting requirements (even for corporations) usually require certain individuals (and corporate employees) to "check the box" on Schedule B of their Form 1040 returns filed each year with respect to their signature authority over these accounts.

For the full story, please view the PDF.