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
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