EYUS Supreme Court reaches pro-filer position in holding that the nonwillful FBAR penalty applies per report, not per account
|Tax Alerts, National/Federal Taxation, B ...|United States, Canada
On 28 February 2023, the United States (US) Supreme Court held in Bittner v United States that the US$10,000 penalty1 for nonwillful failure to file FBAR2 reports imposed under 31 USC Section 5321 applies per annual report/filing, not per account. The 5-4 decision rejected the Government's argument that the nonwillful penalty applies on a per account basis a…
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