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.
- 405 taxpayers identified with unreported foreign account balances totaling roughly $6.2 trillion
- Only 164 of those cases were referred for examination
- Of the 164 referrals, only 12 were actually examined
- Five of those 12 examinations produced results: $39.7 million in additional tax and $80,000 in penalties combined
- 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.