On June 11, 2021, Friedemann Thomma and Marianna Felshtiner published “Takeaways From 2 New FBAR Rulings” in Law360. The following is an excerpt:
U.S. taxpayers who unintentionally fail to report to the Internal Revenue Service their interest in, or signatory authority over, foreign accounts with a total balance of over $10,000 can breathe a little easier. On March 24, the U.S. Court of Appeals for the Ninth Circuit, in U.S. v. Boyd, decided that nonwillful violations of the foreign bank and financial account report, or FBAR, filing obligations are limited to a maximum penalty of $10,000 per year. This decision reversed the U.S. District Court for the Central District of California, which had earlier decided that the $10,000 penalty should be applied on a per-account basis.
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