In a recent case, the Fifth Circuit analyzed whether the $10,000 maximum non-willful FBAR penalty cap applies for each failure to file an annual FBAR or each failure to report an account. In an ...
On November 30, 2021, the Fifth Circuit parted ways with the taxpayer friendly decision of the Ninth Circuit that non-willful penalties are capped at $10,000 per FBAR filing instead of the $10,000 per ...
Forbes contributors publish independent expert analyses and insights. Robert W. Wood is a tax lawyer focusing on taxes and litigation. Often call FBARs—but now known formally as FinCEN Form 114, are ...
The law regarding computation of FBAR penalties is unclear. The United States Supreme Court has agreed to hear a case to settle a conflict among the circuit courts. Until the Supreme Court case is ...
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