On May 16, 2019, Friedemann Thomma and Becca Chappell published "FBAR Taxpayers May Face Steeper Failure-to-File Penalties" in Law360. The following is an excerpt:
Based on a recent U.S. District Court for the Central District of California decision, United States of America v. Jane Boyd, significantly higher financial penalties may now be the reality for United States taxpayers in connection with an unintentional failure to comply with certain foreign financial reporting requirements. Specifically, the court held that a breach of the reports of foreign bank and financial accounts, or FBAR, filing obligations could incur a penalty of up to $10,000 per foreign financial account, rather than only $10,000 per year. In light of this case, United States taxpayers with multiple foreign financial accounts could be at risk for more substantial cumulative penalties if they are not in compliance with the FBAR rules.