On December 20, 2019, the Financial Crimes Enforcement Network (“FinCEN”) issued Notice 2019-1, extending the filing deadline for the Report of Foreign Bank and Financial Accounts, FinCEN Form 114 ...

IMGCAP(1)]There are a number of due dates that don’t apply to all taxpayers, but are easily missed when they do apply and will subject the taxpayer to harsh penalties if they overlook them. For ...

Last week the Ninth Circuit issued a win for taxpayers in US v. Boyd, limiting penalties for non-willful violations of the requirement to file a Report of Foreign Bank and Financial Accounts (FBAR).

The maximum civil penalty for non-willful failure to comply with FBAR reporting requirements is $10,000. 1 However, additional penalties may apply for willful violations. Penalties for a willful ...

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) ...

Practitioners who have clients with overseas accounts should alert them now that the FBAR (Foreign Bank and Financial Accounts Report) form must be received by the Department of Treasury no later than ...