Charles (Chuck) Rubin, in his Rubin on Tax blog, discusses the ability of the IRS to assess and collect FBAR penalties for failure to disclose foreign accounts. The article begins as follows:
The IRS may assess penalties for a person’s failure to file a required FBAR. If the person’s failure to file was willful, the IRS can impose a penalty equal to 50% of the account balance or $100,000, whichever is greater. If an individual dies, can the IRS assess and collect an FBAR penalty for failing to disclose a foreign account?
To see the full article, click: FBAR Penalties Survive Death.