Yesterday, in Bittner vs. United States, 598 U.S. ______ (2023), the Supreme Court resolved a split between the Ninth and Fifth Circuits on the question of whether penalties for non-willful FBAR violations accrue on a per-report or per-violation (i.e., per-account) basis. The facts of the Bittne...
In an opinion filed yesterday in the Southern District of New York, U.S. District Judge Mary Kay Vyskocil denied a motion for summary judgment filed by the government that sought a ruling that a taxpayer's failure to file an FBAR was willful as a matter of law, rejecting the government's position...
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