The IRS has ratcheted up its scrutiny of overseas banks accounts, reported in the 2/1/13 Evisor, by taking the extraordinary step of rescinding the amnesty it had initially granted to some individuals. While only a small percentage have been rescinded, this is an indication of the Service paying close attention. Press reports indicate that the Service is notifying tax attorneys that certain Bank Leumi clients who had disclosed their offshore accounts and were accepted into its criminal amnesty program have, upon review, been disqualified.
The IRS has said that federal law prohibits it from commenting on specific cases. However, there are a number of reasons why an individual may be disqualified, including failing to make a timely, truthful and complete disclosure. Failing to file a Report of Foreign Bank and Financial Accounts (FBAR) annually can result in significant penalties being assessed by the IRS.