For the IRS, the fiscal year ended Sept. 30, 2014, marked the fourth consecutive year of reduced appropriations.1 Substantially reduced funding has had a serious negative impact on taxpayer services,2 and the number of audits dropped 12 percent from the previous fiscal year to its lowest number since 2005.3 Despite these reduced IRS resources, the IRS, along with the Department of Justice and the Financial Crimes Enforcement Network (FinCen) continue to focus strongly on steps to ensure taxpayer disclosure of offshore assets. As of early November 2015, the Treasury Department has signed 78 Intergovernmental Agreements (IGAs) with other countries in furtherance of the enforcement and compliance provisions of the Foreign Account Tax Compliance Act (FATCA). Moreover, IGAs have been reached in substance but are still pending with 34 other countries.4 Under these IGAs, Competent Authority Arrangements (CAAs) continue to be reached between the IRS and foreign taxing authorities to exchange tax information. On September 24, 2015, the IRS announced that it entered into signed CAAs with Australia and the U.K., with the expectation that several other CAAs will be reached in the near future.5 Financial institutions and tax authorities in IGA countries will exchange taxpayer and account holder information using the International Data Exchange Service (IDES) in an effort to enforce offshore account disclosure and prevent money laundering and related crimes.6 Under the terms of some IGAs, foreign financial institutions (FFIs) must register with the IRS7 to disclose information directly to IRS personnel or face a 30 percent withholding tax on U.S.-source payments made to them. Despite doubts from critics about the ability of Treasury to exert such extraterritorial jurisdiction over foreign financial institutions, there are 177,147 FFIs registered with the IRS as of early November 20158 with the total number steadily increasing monthly.