For U.S. citizens, any income earned worldwide must be reported. You must submit a Report of Foreign Bank and Financial Accounts (FBAR) every single year, along with IRS Form 8938. If you have not done this, you may want to participate in the Offshore Voluntary Disclosure Program (OVDP) to limit consequences for non-reporting.

The Department of Justice and the IRS are aggressively pursuing tax evaders and are approaching the crackdown on tax evasion from multiple angles. From targeting bankers to taking criminal action against individual investors, the U.S. government is determined to stop people from parking their money offshore to avoid paying taxes.

The chairman of Parsons & Whittemore, an international pulp mill company, recently pled guilty to a willful failure to declare offshore accounts to the IRS.  The CEO, George Landegger, will be sentenced in May of 2015 and could face up to five years of incarceration. As part of a guilty plea, he has also agreed to pay back taxes of $71,000, as well as a civil penalty of more than $4.2 million. 

The Department of Justice has entered into a deferred prosecution agreement with Bank Leumi Group. Bank Leumi admitted to helping U.S. investors hide money and assets in offshore accounts. Bank Leumi is another in the long line of financial institutions that has been investigated by the Justice Department.  Like most of the banks caught up in an investigation, the bank will turn over information on U.S. account holders.

When a U.S. bank account earns interest or income, the bank sends out a 1099 form alerting the Internal Revenue Service to the money that has been earned. The account holder also gets this 1099 form, which is included with an income tax filing. Of course, offshore banks do not send out these forms. If you have money offshore, you must take on the responsibility of reporting your offshore accounts (and any income those accounts earn) to the Internal Revenue Service (IRS).