Why Holders of Foreign Bank Accounts Need to Worry About IRS’s Voluntary Disclosure Data-Mining Program

Have you ever been surprised by Facebook or LinkedIn’s ability to suggest people to whom you may be connected, when even you had forgotten how you were connected to those people?

Perhaps the social networks’ technology crunched data that you provided on your home town, Boy Scout troop, high school, first job at McDonald’s, or fly-fishing hobby, to find latent connections between you and a long-lost acquaintance.

Use of such data-mining technology is widespread, and the IRS has adopted it to find taxpayers with undisclosed offshore bank accounts.

U.S. taxpayers who are still considering whether to disclose their accounts need ...