If you have one or more foreign bank accounts or other financial accounts, you may be required to file a Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts (FBAR), which is due by June 30, 2011.  The aggregate value of your accounts must be higher than $10,000 to trigger the filing requirement.  The FBAR is required even if the accounts did not generate any interest or taxable income during the past year.

Penalties for willful non-compliance with FBAR reporting requirements are severe: $100,000 or more for civil penalties and $500,000 for criminal penalties, plus possible prison time.

If you failed to file FBAR reports for prior years, you should file them along with a statement explaining why they were filed late.  However, if your account(s) generated any reportable income for the delinquent years, then you should follow the procedures under the IRS 2011 Offshore Voluntary Disclosure Initiative.