As previously blogged by Chuck Rettig (2/9.11), Kathy Keneally (12/12/10) and Bob McKenzie (10/01/10), the IRS has been aggressively pursuing the disclosure of foreign financial information by U.S.

The Foreign Account Tax Compliance Act is fundamental as it affects how you report your finances, especially as an expat abroad. FATCA is why you may need to file a Report of Foreign Bank and ...

The penalty for nonwillful failure to file a Financial Crimes Enforcement Network (FinCEN) Form 114, Report of Foreign Bank and Financial Accounts (FBAR), is assessed per FBAR not timely or properly ...

The "Report of Foreign Bank and Financial Accounts" (FBAR) penalty has been the subject of much litigation. This Holland & Knight alert focuses on the non-willfulness element of 31 U.S.C. § 5321(a)(5) ...

Today, the Supreme Court issued a 5-4 decision in Bittner v. United States, ruling that the Bank Secrecy Act’s $10,000 maximum penalty for a nonwillful failure to file a timely and accurate FBAR ...

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 ...