The IRS is continuing to focus its resources and attention on unreported foreign assets. Foreign financial institutions are implementing and executing procedures to identify US taxpayers and report them to the IRS. At the same time, the IRS is getting more aggressive about imposing penalties for failure to report foreign assets, including FBAR penalties and other foreign asset reporting penalties. This session will: 1. Summarize those development, discuss penalty defenses and provide hot tips on how to avoid or minimize foreign asset reporting penalties. 2. Understand what the IRS is doing now with respect for foreign asset reporting penalties. 3. Learn how the penalties are imposed and how to defend against them. 4. Develop strategies for advising clients with unreported foreign assets.