Foreign financial institutions will begin reporting to the IRS, potentially exposing some U.S. taxpayers to substantial penalties for FBAR non-compliance.

Foreign financial institutions will be required to enter into an agreement with the IRS by June 30, 2013, for reporting and withholding requirements to begin on Jan. 1, 2014, potentially exposing some U.S. taxpayers to substantial penalties for FBAR non-compliance.
 
Taxpayer obligations under FATCA and FBAR are distinct and may overlap, requiring some taxpayers to file both Form 8938 and TD F 90-22.1.
 
Red flags indicating that the client may have financial interests in another country should be noted and pursued. In hindsight it can be argued that the CPA should have done just that.