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Foreign Bank Account Report › Tax Audits

Holland & Knight LLP

Same Statute, Same Form, Different Penalties: Welcome to FBAR Litigation

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The "Report of Foreign Bank and Financial Accounts" (FBAR) penalty has been the subject of much litigation. This Holland & Knight alert focuses on the non-willfulness element of 31 U.S.C. ยง 5321(a)(5)(B). Both the U.S. Court...more

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