In the past decade, the Internal Revenue Service has placed an increased 
emphasis on international compliance, both in added enforcement of existing 
forms and promulgation of new requirements.  The Service has offered what has
been tantamount to a “grace period” for compliance, offering voluntary 
disclosure programs for retroactive failures.  Increased indicia exist 
showing that this “grace period” may be expiring, with assessments for 
failures more common prospectively.  

This seminar will address penalty risks and assessment mechanisms for 
failures to meet international reporting requirements, including FinCEN 
Report 114 (commonly referenced as the FBAR).