IRS and the Justice Dept. are on the prowl for undisclosed foreign accounts, devoting resources to get U.S. owners of the accounts to timely report them each year if the total value exceeded $10,000 at any time during the prior year. Penalties for nonreporting are stiff: $10,000 apiece for nonwillful violations… the larger of $100,000 or 50% of the highest balance in the account for willful failures. If you haven’t reported overseas accounts for 2018, you can still do so. Filers who missed the April 15 deadline to electronically submit FinCEN Form 114 to disclose foreign financial accounts automatically have until Oct. 15 to file the form. In its war on hidden foreign accounts, IRS’s focus can go beyond banks. Law firms can get caught up, too. A federal court has OK’d an IRS summons allowing the agency to get names of a law firm’s clients after IRS audited a person who used the firm to set up foreign accounts and overseas entities to avoid U.S. tax. The firm claimed the summons sought data protected by attorney-client privilege, but that argument fell flat with the court (Taylor Lohmeyer Law Firm, D.C., Texas).