American Jobs Creation Act of 2004 (Tax focus) – Changes to Penalties for Failure to Report Foreign Financial Accounts
On October 22, 2004, the American Jobs Creation Act of 2004 (H.R. 4520) (“AJCA”) was signed into law. This new federal tax law includes numerous provisions of particular interest to individuals and businesses. One such provision is Section 821, which modifies penalties for failure to report foreign financial accounts to the Treasury Department. Not only does the AJCA increase existing penalties for a willful failure to report a foreign financial account, but also imposes a new civil penalty on any person that violates the reporting requirements regardless of willfulness. View full article (PDF).