Is Your Client the Subject of an FBAR Examination?

Has a client received a letter from the IRS asking to schedule an appointment to examine the client’s compliance with the requirement to file FinCEN Report 114, Report of Foreign Bank and Financial Accounts (FBAR)? Although an FBAR examination is not an income tax examination, the client may be liable for penalties for failure to comply with 31 U.S.C. Section 5314.