Back in 2007, the IRS and U.S. Department of Justice (DOJ) were hot on the heels of Switzerland-based mega financial institutions like UBS, Credit Suisse, and Wegelin for assisting wealthy Americans in hiding billions of dollars in foreign accounts. Part of the fallout included the enactment of the Foreign Account Tax Compliance Act (FATCA) in 2010, which requires all foreign banks to file reports with the IRS on all American accounts over $50,000. Americans must also file the disclosure separately on their yearly returns. Failure to report results in a 40 percent penalty for the account holder and even…