re: 77,000 different foreign banks in 70 countries reporting to IRS now

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I understand nc. This guy is an accountant that specializes in international transactions.

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I know. Hence . . .

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you'd claim this is in your wheelhouse

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He seems to accounting here, what TUba is to Physics.

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The vast majority of fatca disclosures have more than just savings accounts reported

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It would be hard to seriously imagine a tax avoidance strategy involving large assets sitting in a bank's savings account. That was the point. Hard to imagine it even in higher interest locales like Pakistan or Brazil. Much less in the sub1%ROI range most 1st world accounts would render.

Risk/return compared with Tax Free Munis 5yr annualized running at ~6.5% would be nuts. Given other tax avoidance options, it's hard to believe ANYone with ability to accrue substantial assets would be stupid enough to drop them in a Cyprus-type Bank Savings Account for sole purpose of US tax avoidance. In terms of invitation for disaster, IRS discovery would rank way down the list.

Now accounts for money laundering, dummy corporations, pass-thru investment entities, etc. are obviously a different deal.

What I'd like to know is the number of Americans with foreign bank accounts vs the number suspected of fraud. I'd bet both are low with the fraud ratio being substantially off the "1" figure the OP (or TnM's "exponentially" comment) would imply.

My cynical side sees this forwarded as little more than a salacious attention distracting story designed to get folks like the OP excitedly rubbing their hands together, anticipating another strike at American affluence. The story comes in advance of Select Committee Hearings, along with an anticipated IRS-unfriendly November election result. Strip away the shiny paint, and there's no there there.

As an aside, it seems any financial institution marketing itself to the taxhaven crowd would simply fractionate larger accounts to sub$50K size, and dodge reporting.