Internal Revenue Service building in Washington, D.C, on Jan. 12, 2022. Photo: Diego M. Radzinschi/ALM 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.
March 24, 2023 at 10:00 AM
8 minute read
On Feb. 28, 2023, the U.S. Supreme Court handed a rare victory to taxpayers facing extremely harsh IRS penalties for failing to timely or accurately file Foreign Bank Account Reports (FBARs).
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