News & Analysis as of

Foreign Financial Accounts Supreme Court of the United States

Buchalter

FBARs, FATCA, and Foreign Nationals: Where are We Headed?

Buchalter on

There has been a legal shakeup this summer in the world of “FBARs”—Reports of Foreign Bank and Financial Accounts. New developments have been popping up nearly every week, whether from a court decision, as a result of a...more

Cole Schotz

Supreme Court Rules Non-Willful FBAR Penalties are Calculated on a Per Report Basis

Cole Schotz on

On February 28, 2023, in a significant tax case, Bittner v. US, the U.S. Supreme Court held that a U.S. person who fails to file his or her FBAR on a non-willful basis only is subject to a single penalty on the failure to...more

Fox Rothschild LLP

U.S. Supreme Court Rules Against Government in FBAR Penalty Case

Fox Rothschild LLP on

The U.S. Supreme Court has ruled that the $10,000 penalty for a nonwillful violation of the foreign bank account reporting rules in the Bank Secrecy Act applies on a “per-form” basis, not a “per-account” basis, handing...more

Holland & Hart LLP

Supreme Court Rules that FBAR Penalties are Per-FBAR Form, Rejecting IRS's Per-Account Position

Holland & Hart LLP on

Today, the Supreme Court issued a 5-4 decision in Bittner v. United States, ruling that the Bank Secrecy Act’s $10,000 maximum penalty for a nonwillful failure to file a timely and accurate FBAR report accrues on a per-FBAR...more

Jackson Walker

Docket Check: US Supreme Court to Decide Key Criminal and Regulatory Cases This Term

Jackson Walker on

The U.S. Supreme Court began its new term last week and is poised to answer some major questions in criminal and regulatory law. This term, the Court is tasked with construing the Bank Secrecy Act’s penalty provision, ruling...more

Levenfeld Pearlstein, LLC

U.S. Supreme Court to Hear Foreign Financial Account Penalty Case

$50,000 or $2.72 million? Those are the penalty amounts for the non-willful failure to timely file to report foreign financial accounts at issue in U.S. v Bittner, which will be argued before the U.S. Supreme Court in...more

Fox Rothschild LLP

US Supreme Court to Review Non-willful FBAR Penalty

Fox Rothschild LLP on

The U.S. Supreme Court has agreed to resolve a dispute concerning the maximum applicable penalty for non-willful violations of the foreign bank account reporting statute. The Ninth and Fifth circuit courts are split on...more

Saul Ewing LLP

White Collar Watch - March 2013

Saul Ewing LLP on

In This Issue: - Eleventh Circuit Holds that Production of Foreign Bank Account Records May be Compelled in Criminal Investigation Under Required Records Exception to Fifth Amendment Privilege - Supreme Court...more

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