The Foreign Account Tax Compliance Act (FATCA) is designed to aid U.S. efforts to improve tax compliance involving foreign financial assets and offshore accounts.  Under FATCA, U.S. taxpayers with specified foreign financial assets that exceed certain thresholds must report those assets to the IRS.  This reporting will be made on Form 8938, which taxpayers attach to their federal income tax return, starting this tax filing season.  In addition, FATCA will require foreign financial institutions to report directly to the IRS information about financial accounts held by U.S. taxpayers, or held by foreign entities in which U.S. taxpayers hold a substantial ownership interest.  Taxpayers and institutions need to take steps now to avoid potential criminal repercussions arising from FATCA.