Joseph B Shumofsky

Joseph B Shumofsky

March 24, 2023 | New Jersey Law Journal

Finally, a Taxpayer Victory in an FBAR Penalty Case—But Will It Change Anything?

In a 5-4 decision in Bittner v. United States, the Supreme Court held that the $10,000 per violation non-willful FBAR penalty, contained in 31 USC § 5321, applies only to each FBAR and not to each account listed in that FBAR.

By Richard J. Sapinski and Joseph B. Shumofsky

8 minute read