The IRS is aggressively looking for taxpayers who don't report their foreign accounts, willfully or not.  They are also looking at tax professionals to see what guidance they provided to their clients.

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In our global world, you must properly interview ALL clients and document, document, document.  Gone are the days you can ask one question "Do you have a foreign bank account?" and be done.

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You want to properly serve your clients, and of course, you want to protect yourself.  The penalties are ENORMOUS, and between limited IRS guidance, changes brought on by recent Tax Acts, and misinformation all over the internet, your head is swirling.