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Internal Revenue Code (IRC) Section 6103 authorizes the IRS to share tax information by entering into agreements with governmental agencies for tax administration purposes. Comparable laws allow agencies to share their information with the IRS.
One of easiest ways for the IRS to discover your foreign bank account is to have the information hand-fed to them from various Foreign Financial Institutions.
According to the IRS, it will only share information with foreign countries which meet its stringent safeguard, privacy, and technical standards, and it has the ability to halt transmissions if it believes the standards aren't being met.
One of the main catalysts for the IRS to learn about foreign income which was not reported, is through FATCA, which is the Foreign Account Tax Compliance Act. In accordance with FATCA, more than 300,000 FFIs (Foreign Financial Institution) in over 110 countries actively report account holder information to the IRS.
Tax information exchange agreements (TIEA) provide for the exchange of information on request relating to a specific criminal or civil tax investigation or civil tax matters under investigation.