FBAR – Fifth Circuit, Non-Willful Penalty Multiplies “Per Account” in Bittner Case

Ka’Ching! It’s a win for the Internal Revenue Service (IRS)! At the end of November, in United States v. Bittner, (No. 20-4059, 5th Cir. 11/30/21), the Fifth Circuit overruled the lower court and held that the FBAR non-willful US$10,000 penalty applies on a per account rather than a per form basis.  The taxpayer was hit … Continue reading FBAR – Fifth Circuit, Non-Willful Penalty Multiplies “Per Account” in Bittner Case