The Court is expected to clarify whether non-willful foreign bank account reporting violations apply per form or per account.
that a Romanian-born businessman and investor with foreign bank accounts was liable for the penalties based on each of the dozens of accounts he failed to report each year rather than on the singleThe Bittner decision is in direct conflict with a Ninth Circuit ruling which held that non-willful FBAR penalties apply per form. See. If you have dealt with the IRS, you may know that penalties can add up, and that how you calculate them can matter—a lot.
As an American citizen or green card holder, you must report your worldwide income, and that includes interest income from bank accounts overseas. If you don’t, there are taxes, interest and penalties. On top of these tax penalties, there are bigger and uglier penalties for failing to file bank account reporting forms known as FBARs. Another name is FinCEN Form 114. These annual forms are not filed with the IRS, they are filed with the Financial Crimes Enforcement Network, part of the U.S.
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