Taxpayers with foreign accounts worth more than $10,000 in the preceding year must file a “Report of Foreign Bank and Financial Accounts” (FBAR). Failure to file can result in hefty penalties, though if non-willful, penalties are limited. Previously, a U.S. District Court ruled that the penalty is assessed per FBAR form. That would mean multiple accounts could be reported on one form, which would reduce the penalty. But on appeal, the 5th Circuit Court reversed the District Court and found the penalty applies per account. The Appeals Court assessed a penalty for the non-willful failure to report 41 accounts for multiple years, for a total penalty of $2.72 million. (Bittner, 11/30/21)


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