The U.S. government is continuing to expand its efforts to increase compliance by U.S. persons with regard to disclosures of financial accounts outside of the United States. As a result, U.S. persons with previously undisclosed financial accounts (and/or income) outside of the United States should be aware that the government has made it a priority to enforce laws requiring disclosure of such accounts and reporting of such income.

A looming Aug. 31, 2011, deadline by which to complete a voluntary disclosure of such accounts and/or income to the Internal Revenue Service (IRS) is discussed below, and should be taken seriously by U.S. taxpayers whose compliance with disclosure, reporting and/or tax payment obligations has been imperfect. Failure to participate in the formal voluntary disclosure program leaves such persons vulnerable to both civil and criminal penalties.

Federal Mandate