(As published in the Baltimore Business Journal on February 27, 2015)
Yes, if 1) you are a U.S. citizen, resident alien, or certain non-resident alien that had an interest in a specified foreign financial account or asset (SFFA) in 2014; 2) the aggregate value exceeds the reporting threshold limits; and 3) one of your SFFAs was held at a FFI that has registered to participate in the reporting program with the IRS. Since tax year 2011, taxpayers with an interest in a SFFA must file a Form 8938, which must be filed with your tax return. Failure to file a Form 8938 may result in a $10,000 penalty, among other penalties, and may extend the time the IRS has to audit your tax return. By September 30, 2015, registered FFIs (including over 100,000 banks, investment institutions, and certain types of insurance companies) must report the name, address, social security number, account number and account value to the IRS for their U.S. account holders. This means the IRS will be able to match the information reported by the FFI with your tax return, just like the IRS matches information reported by U.S. financial institutions on Forms 1099, with your tax return.
If you had, or may have had an interest in a SFFA in 2014, or prior, you should contact a qualified tax professional to discuss how FATCA impacts your U.S. income and information reporting requirements.