“A willful failure to file is considered a felony punishable by five years in prison. Holders of unreported foreign accounts have more than jail to fear. The IRS has proven itself very adept at finding taxpayers that have not filed an FBAR. Those that are caught can expect both a tax bill and a penalty assessment of the greater of $100,000 or half the highest balance in the account. Making things worse for taxpayers is next year’s looming FATCA law. If the IRS thinks you moved or renamed your account to avoid detection, chances of criminal prosecution increase dramatically. The Quiet Disclosure strategy not only doesn’t work, it sets up taxpayers for a huge interest and penalty bill.”
http://isaacbrocksociety.ca/2013/09/09/american-threats-against-innocent-expats-is-increasing/
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