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Tag: foreign bank account

Solicitor General Wants US Supreme Court to Decide Whether the FBAR “Nonwillful” Penalty is “Per Form” or “Per Account”  

My earlier blog posts discussed the split in the circuit courts whether the FBAR $10,000 civil nonwillful penalty is to be applied on a “per account” basis rather than “per form”.  The crux of the matter involves conflicting statutory interpretations by the 5th and 9th circuit courts of the Bank Secrecy Act (BSA) (31 U.S.C. … Continue reading Solicitor General Wants US Supreme Court to Decide Whether the FBAR “Nonwillful” Penalty is “Per Form” or “Per Account”   →

us-tax.org Accidental Americans, Americans Overseas, FBAR, Offshore Accounts Leave a comment May 26, 2022May 25, 2022 6 Minutes

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Virginia La Torre Jeker, J.D. 

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