In its recent decision in United States v. Leeds, the United States District Court for the District of Idaho upheld the application of willful penalties against a deceased husband for failing to report certain foreign bank...more
Conflicting Decisions: In August, the U.S. Court of Appeals for the Eleventh Circuit held in United States v. Schwarzbaum that a monetary civil penalty imposed for willfully failing to file a foreign bank account report...more
For years, FBAR litigants have made the commonsense argument that large willful FBAR penalties, which can exceed the value of the unreported foreign accounts themselves, violate the excessive fines clause of the Eighth...more