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December 2021 » Recent Developments in FBAR Jurisprudence
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Usman Mohammad, JD, and Michael Gelb
Failing to report foreign bank accounts on a Report of Foreign Bank and Financial Accounts (FBAR) form can carry severe financial consequences. The civil penalty for non-willful violations of the FBAR reporting requirement is $10,000. The civil penalty for willful violations of the FBAR reporting requirement is the greater of $100,000 or 50% of the account balance. In order to properly advise taxpayers regarding those consequences, tax professionals should be aware of recent court developments regarding FBAR penalties.
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