FATCA law is designed to improve tax compliance involving foreign financial assets and offshore accounts. Penalties for non-compliance are potentially severe. Under FATCA, U.S. taxpayers with specified foreign financial assets that exceed certain thresholds must report those assets to the IRS on Form 8938. 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.