If you have any funds invested with foreign financial institutions, it is imperative you ensure you are in compliance now, and have complied in the past, with FATCA, with mandated annual FBAR filings, and with all other tax rules and requirements. If you have not been in full compliance with tax obligations, you should speak with a Boston tax law firm as soon as possible to explore your options for resolving your unresolved tax issues through participation in amnesty programs such as the Offshore Voluntary Disclosure Program.

If you did not file all of your required Reports of Foreign Bank and Financial Accounts and you did not otherwise comply with U.S. tax rules in connection with offshore accounts, you face a substantial risk of civil penalties and even criminal prosecution. The IRS is aggressively fighting offshore tax evasion, and many foreign banks are helping the IRS by providing them with accountholder information in exchange for avoiding criminal penalties for helping American to evade their taxes.

If you have offshore funds invested under the control of Swiss Life Holding AG, you need to be aware that Swiss Life is involved in discussions with the U.S. government that could likely lead to your financial details being disclosed. Swiss Life Holding is discussing the U.S. affiliated accounts under its control, as part of an investigation into its cross border business. The U.S. government is interested in many of the different products and services offered to offshore investors, including insurance wrappers.

If you have funds in an offshore bank account, keeping your investments private may have been one of the goals of opening the offshore account. Unfortunately, in recent years, it has become increasingly difficult to keep your personal account information from falling into the hands of the IRS or otherwise being outed.

Canada, the United States, and many additional countries throughout the world have begun to aggressively pursue investigations and claims against investors who are accused of keeping funds offshore to evade their tax obligations.