Statute
FBAR
239 published works
Tax Controversy Report
U.S. Supreme Court Rules Against Government in FBAR Penalty Case
The U.S. Supreme Court has ruled that the $10,000 penalty for a nonwillful violation of the foreign bank account reporting rules in the Bank Secrecy act applies on a “per-form”…
Legacy Advisors
Non-Willful Failure to File FBAR Under BSA Should Be Penalized on a Per-Report Basis, Supreme Court Rules for Taxpayer Against IRS
By Jared E. Dwyer, Barbara T. Kaplan, Courtney A. Hopley
The applicable penalty for the non-willful failure to file a foreign financial account is applied on a per-form basis, not a per-account basis, the U.S. Supreme Court decided Feb. 28…
Wills, Trusts & Estates Prof Blog
Supreme Court Rules In Taxpayer’s Favor On FBAR Penalties
The U.S. Supreme Court ruled yesterday that penalties for non-willfully failing to file, or inaccurate filing, a Report of Foreign Bank and Financial Accounts (FBAR) Form 114 applies to each…
Wills, Trusts & Estates Prof Blog
Supreme Court Rules In Taxpayer’s Favor On FBAR Penalties
The U.S. Supreme Court ruled yesterday that penalties for non-willfully failing to file, or inaccurate filing, a Report of Foreign Bank and Financial Accounts (FBAR) Form 114 applies to each…
Tax, Trusts & Estates Law
Important Supreme Court Decision will Decide how Non-Willful FBAR Penalties are Calculated
This fall, the Supreme Court is set to hear an important case regarding the interpretation of the law that provides for penalties for failing to file an FBAR. The case…
Tax Controversy Report
US Supreme Court to Settle Long-Disputed FBAR Penalty Issue
Matthew D. Lee authored the Bloomberg Tax article, "US Supreme Court to Settle Long-Disputed FBAR Penalty Issue." View the full article.
Tax Controversy Report
US Supreme Court to Review Non-willful FBAR Penalty
The U.S. Supreme Court has agreed to resolve a dispute concerning the maximum applicable penalty for non-willful violations of the foreign bank account reporting statute. The Ninth and Fifth circuit…
Dollars & Sense
Supreme Court Will Hear Non-Willful FBAR Penalty Dispute
On June 21, 2022, the United States Supreme Court agreed to hear a dispute involving split decisions among the circuit courts on non-willful penalties. The Fifth Circuit parted ways with…
Rubin On Tax
FBAR Case Reversed – Nonwillful Filing Penalties Based on Number of Accounts Not Reported
Back in 2000, I wrote here about a case where a taxpayer did not report multiple foreign accounts on an FBAR. The question for the court was whether the $10,000…
Dollars & Sense
Non-Willful FBAR Penalties Will be Much Higher in the Fifth Circuit
On November 30, 2021, the Fifth Circuit parted ways with the taxpayer friendly decision of the Ninth Circuit that non-willful penalties are capped at $10,000 per FBAR filing instead of…