There has been a potentially landscape-altering decision out of the Fifth Circuit Court of Appeals (Court) regarding Reports of Foreign Bank and Financial Account (FBAR) penalties. In United States v. Bittner, that Court has held that each failure to report a qualifying account is a separate violation. This is a significant split from the Ninth [...]
In 1970, Congress passed the Bank Secrecy Act. The purpose of that Act was to combat money laundering. It granted broad authority to the Internal Revenue Service to enforce the Act. This meant the implementation of the Report of Foreign Bank and Financial Accounts (FBAR). The FBAR was the IRS’s attempt to ensure the maintenance [...]