The U.S. IRS has published a memorandum dated 23 May 2018 concerning the burden of proof and standard for willfulness in relation to civil violations of the Report of Foreign Bank and Financial Accounts (FBAR) requirements. In general, every United States person that has a financial interest in, or signature or other authority over, a financial account in a foreign country must report the account in the FBAR when the aggregate value of all foreign financial accounts exceeds USD 10,000 at an…