US Expat Wealth

August 28, 2026

The IRS Found $6.2 Trillion Unreported. It Fined $80,000.

A 2026 TIGTA audit found the IRS identified 405 Americans with $6.2 trillion in unreported foreign accounts under FATCA's Campaign 896, but examined only 12 cases and assessed just $80,000 in penalties despite spending roughly $683 million implementing FATCA's data infrastructure. The filing requirement itself hasn't changed—only the odds of examination, which remain a poor bet.

What the TIGTA Report Actually Found

In April 2026, the Treasury Inspector General for Tax Administration (TIGTA)—the independent watchdog that audits the IRS's own operations—released Report No. 2026-308-009. It examined Campaign 896, the IRS initiative that uses data collected under the Foreign Account Tax Compliance Act (FATCA, the 2010 law requiring foreign banks to report accounts held by Americans directly to the IRS) to find US taxpayers who should have filed Form 8938 (the Statement of Specified Foreign Financial Assets, a form that reports foreign accounts and investments above certain thresholds) but didn't. The findings are striking, and worth understanding clearly—not because they change what you owe, but because they clarify how the enforcement machine actually works.

$6.2 trillion

Unreported foreign account balances TIGTA says the IRS identified among 405 Form 8938 nonfilers under Campaign 896

That $6.2 trillion figure represents the combined balances FATCA data flagged as belonging to 405 taxpayers who appear not to have filed Form 8938 at all. That's the starting point of the funnel. What happened next is the real story.

  1. 405 taxpayers identified with unreported foreign account balances totaling roughly $6.2 trillion
  2. Only 164 of those cases were referred for examination
  3. Of the 164 referrals, only 12 were actually examined
  4. Five of those 12 examinations produced results: $39.7 million in additional tax and $80,000 in penalties combined
  5. 241 nonfilers with average unreported balances of about $377 million received only a soft, educational letter—no examination, no $10,000 Form 8938 nonfiling penalty

Why $683 Million Bought So Little Enforcement

TIGTA reports that the IRS has spent roughly $683 million building and implementing FATCA's data infrastructure since the law took effect. That spending built the pipeline—banks around the world, including in Switzerland, now report account information on US persons directly to the IRS. But TIGTA's core conclusion is that the IRS has the data and lacks the operational capacity to turn it into actual examinations. The report also found the IRS failed to assess roughly $4 million in penalties it was already authorized to collect on cases it had reviewed. In plain terms: the intelligence-gathering side of FATCA is working. The follow-through side is not, at least not yet.

Why This Isn't a Green Light to Skip Filing

The enforcement gap doesn't change the rule

It's tempting to read a low examination rate as low risk. That's the wrong takeaway. Filing obligations under Form 8938 and the separate FBAR (the foreign bank account report, filed with FinCEN rather than the IRS) haven't changed one bit—TIGTA's report is about enforcement capacity, not about whether the requirement applies to you. Data gaps get closed, staffing shifts, and IRS priorities move faster than most taxpayers expect. If you want the specifics of what triggers an FBAR filing and when it's due, FBAR Filing for Americans in Switzerland: 2026 Deadlines and Rules walks through the current thresholds and dates.

What This Means for Americans Banking in Switzerland

Switzerland operates under a Model 2 FATCA agreement, which means Swiss banks report account information on US persons directly to the IRS rather than through the Swiss government. That data has been flowing for years, which is exactly the data TIGTA says the IRS is sitting on but not fully using. The IRS is also increasingly using automated systems to cross-reference what banks report against what taxpayers actually file—a process that doesn't require the staffing TIGTA says is currently limiting examinations. For a closer look at how that cross-referencing works, How the IRS Uses AI to Cross-Reference FATCA and FBAR Data (and What It Means for You) breaks down what's changing on that front.

The Form 8938 Basics, in Plain English

If you're an American living in Switzerland, the reporting threshold for Form 8938 is higher than it is for people living in the US—recognizing that holding foreign accounts is normal life abroad, not a red flag. As a single filer living abroad, you generally need to file if the total value of your specified foreign financial assets exceeded $200,000 on the last day of the tax year, or $300,000 at any point during the year (thresholds are higher for married couples filing jointly). This is separate from and in addition to the FBAR, which has its own $10,000 threshold and its own filing deadline.

  • Form 8938 threshold for Americans abroad (single filer): $200,000 on the last day of the year, or $300,000 at any point during the year
  • FBAR threshold: $10,000 combined across all foreign accounts, at any point during the year
  • Form 8938 nonfiling penalty: $10,000 initial penalty, with additional penalties of up to $60,000 for continued nonfiling after IRS notice
  • FBAR and Form 8938 are separate filings with separate rules—filing one does not satisfy the other

If You're Already Filing: What Changes for You? Nothing.

If you've been filing Form 8938 and your FBAR each year, this report doesn't ask anything new of you. It confirms that the system built to catch nonfilers is still maturing, which is one more reason accurate, on-time filing remains the calmer path—you're not depending on the IRS's examination capacity staying limited forever.

If You've Fallen Behind: There's a Constructive Path

If you realize while reading this that you should have filed Form 8938 or an FBAR in a prior year and didn't, that's a fixable, common situation—not a crisis. The IRS has established procedures for taxpayers who come forward before being contacted, and the practical difference between addressing a gap on your own terms versus waiting for a letter is significant. This is exactly the kind of situation where getting a clear picture of what's owed and what process fits your facts matters more than guessing.

One place, both systems

At US Expat Wealth, we work specifically with Americans in Switzerland navigating US filing obligations alongside Swiss banking and pension realities—because the two systems rarely line up on their own, and figuring that out shouldn't fall entirely on you.

Frequently asked questions

Does the TIGTA report mean the IRS won't enforce Form 8938 against me?
No. TIGTA found that the IRS currently lacks the operational capacity to examine most flagged cases, but that's a resource constraint, not a policy change. The filing requirement and the penalties for nonfiling remain fully in effect, and enforcement capacity can expand.
What is Campaign 896?
Campaign 896 is the IRS enforcement initiative examined in the TIGTA report. It uses FATCA data reported by foreign banks to identify US taxpayers who appear to hold foreign financial assets above the Form 8938 threshold but haven't filed the form.
What's the difference between Form 8938 and the FBAR?
Form 8938 is filed with your federal tax return and covers specified foreign financial assets above thresholds that are higher for Americans living abroad ($200,000/$300,000 for single filers). The FBAR is filed separately with FinCEN and covers foreign accounts with a combined value over $10,000 at any point in the year. You may need to file one, both, or neither depending on your accounts.
Does Switzerland's FATCA agreement mean Swiss banks report to the IRS automatically?
Yes. Switzerland has a Model 2 FATCA agreement, meaning Swiss financial institutions report account information on US persons directly to the IRS rather than routing it through the Swiss government first.
What happens if I should have filed Form 8938 in past years and didn't?
This is a common and fixable situation. The IRS has established procedures for taxpayers who come forward proactively, and the approach differs depending on whether the nonfiling was willful or not. Getting personal guidance on which process fits your facts is the right next step—this isn't something to resolve by guessing.

Keep reading