A Tough IRS Message for Clients of 10 Offshore Banks – WSJ. This was an interesting article in the Wall Street Journal. The IRS and U.S. Department of Justice are definitely stepping up their game in going after those with undisclosed foreign accounts. The DOJ is progressing with its enforcement of the laws and wants people to come forward to voluntarily disclose their accounts. The modified OVDP does provide some some opportunities for those that qualify for the streamlined filing process. The fines are going up to 50% from 27.5% of the highest account balance if it is publicly known that the bank or other firm where the funds are located are under investigation by the IRS or the U.S. Justice Department.