Recent Developments Encourage Voluntary Correction Of Foreign Financial Account Reporting Violations

These initiatives offer welcome relief to non-filers who have been considering voluntary disclosure, but have been reluctant to proceed.

McDermott's 2006 On The Subject entitled " Foreign Financial Account Holders: Prepare to File" detailed the annual information reporting requirements for individuals and entities with a financial interest in or signatory or other authority over a foreign bank or financial account (FBAR). The FBAR reporting requirements apply to any such foreign accounts where the aggregate balance exceeds $10,000 at any time during the year. As previously noted, the FBAR requirements are broad in their reach and the penalties for non-compliance were significantly increased in 2004.