Supreme Court Holds FBAR Penalties Are Calculated Per Report
Constitutional Law Reporter
APRIL 4, 2023
Supreme Court held that the penalty for the nonwillful failure to file a Report of Foreign Bank and Financial Accounts (FBAR) is $10,000 per report rather than per account. Bittner challenged that penalty in court, arguing that the BSA authorizes a maximum penalty for nonwillful violations of $10,000 per report, not $10,000 per account.
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