Recently, many tax return preparers have learned that a number of their clients failed to report their interest in a foreign bank account, corporation or trust to the IRS.  Because the Foreign Asset Tax Compliance Act requires foreign financial institutions to report their U.S. depositors to the IRS, the IRS is more likely to discover non-reporting taxpayers.  Furthermore, in light of more stringent reporting requirements, recent publicity and IRS enforcement action focused on non-reporters of foreign assets, all tax preparers should ask their clients whether they have failed to report foreign assets to the IRS.  When a practitioner learns of a client’s unreported foreign assets, what should he or she do?