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FinCEN Form 114, better known as a Report of Foreign Bank and Financial Accounts (FBAR), is a federal tax form that must be filed by taxpayers who own or have a financial interest in certain types of offshore accounts. The FBAR rules are complicated and failing to properly file FBARs when required can lead to substantial IRS penalties.

In 2018, the Internal Revenue Service (IRS) joined forces with tax authorities in four other countries to form the Joint Chiefs of Global Tax Enforcement, known as the J5. In 2020, the J5 announced its first multinational tax evasion investigation, and it warned that banks and taxpayers should expect more similar efforts going forward.