A failure to file an annual Report of Foreign Bank and Financial Accounts (Form TD F 90-22.1) has significant consequences for investors with foreign bank accounts, warn Washington DC IRS lawyers. One recent case illustrated just how severe those consequences can be. 

Because of this landmark case, other foreign banks may now enter into plea agreements with the U.S. Government.

Disclosure to the IRS through the IRS Amnesty Program must occur before the U.S. Taxpayer is contacted by the IRS.