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Background

Sometimes when the IRS rolls a hand grenade at you, the implications are not immediately clear. This is the case with a new Form
8938 where ownership of foreign financial assets is disclosed.

This filing requirement is directly related to the scandal at UBS where the bank was forced to turn over information on 4,700 U.S.
citizens with accounts. From 2009 through 2011 the IRS had an amnesty program where individuals could voluntarily declare
unreported foreign income and avoid criminal prosecution. About 20,000 individuals elected to participate in the program.

The amnesty program amounted to shaking the tree. The real enforcement now starts with expanded reporting of foreign assets.