08
Jun
Initially published in JD Supra |
A debate over penalties for non-willful failure to disclose all of an individual’s or business’ foreign bank accounts may reach the Supreme Court, if a Department of Justice request is granted, according to its recently filed brief. At issue: should the maximum $10,000 Foreign Bank Account Reporting (FBAR) penalty apply on a per-account basis, or rather than in one unified annual basis.
Fifth and the Ninth Circuit Courts have produced dueling rulings that could mean...