The IRS recently issued a memorandum entitled, “Interim Guidance for Report of Foreign Bank and Financial Accounts (FBAR) Penalties.” As explicitly stated in the memorandum, its purpose is to improve the administration of the IRS’s FBAR compliance program. How so? By implementing new procedures. This guidance affects two specific IRMs: 4.26.16 and 4.26.17.

For those who thought that the IRS might have waited a couple months before making these procedures effective so as to allow tax practitioners sufficient time to get up to speed and to work out any “kinks,” that was wishful thinking. Far from enacting a “grace period,” these new procedures went into effect the very day they were published, which just so happened to be May 13, 2015. Thus, this guidance is effective immediately and Read More