A district court held that the government violated a taxpayer’s Seventh Amendment right to a civil jury trial in an FBAR case ...

In Boyd, the taxpayer first disclosed her interest in several financial accounts located in the United Kingdom in connection with her participation in the IRS's 2012 Offshore Voluntary Disclosure ...

The Report of Foreign Bank and Financial Account, or FBAR, is an annual informational tax report that must be filed by certain U.S. individuals and legal entities to report their foreign bank accounts ...

Over the past 10 years, this column has detailed the Internal Revenue Service’s aggressive pursuit of taxpayers with undisclosed offshore accounts. In addition to criminal prosecutions, the IRS’s ...

On Feb. 28, 2023, the U.S. Supreme Court issued its opinion in Bittner v. United States, which focused on the correct penalty amount for non-willful violations of the foreign bank and financial ...

The Supreme Court is set to decide how penalties are determined for non-willful failure to comply with FBAR filing requirements. On June 21, 2022, the Supreme Court of the United States (SCOTUS) ...

The Supreme Court has docketed Bittner v. U.S. for its fall calendar, setting it to resolve a split between the Fifth Circuit and the Ninth Circuit on the penalty for violation of the Report of ...

Prior to 2023 and 2024, taxpayers faced significant challenges in contesting penalties for failing to report foreign accounts via the Foreign Bank and Financial Accounts (FBAR). However, recent court ...

The U.S. Supreme Court Building in Washington, D.C., is the seat of the Supreme Court of the United States and the Judicial Branch of government. (Photo by Robert Alexander/Getty Images) Alexandru ...

The U.S. Supreme Court held Tuesday in a 5-4 decision that the $10,000 penalty for a nonwillful failure to file a Report of Foreign Bank and Financial Accounts (FBAR) for foreign accounts accrues per ...