Introduction: Streamlined Procedure As an attorney specializing in international tax law, it is crucial to understand the consequences and available options for individuals who have failed to file their Foreign Bank and Financial Accounts (FBAR) reports. Failure to comply with FBAR reporting requirements may result in severe penalties. Fortunately, the Internal Revenue Service (IRS) offers
FBAR Penalties
Supreme Court Resolves FBAR Penalty Dispute: Per-Report Basis Confirmed
Introduction to the FBAR Penalty Dispute: In a significant decision, the U.S. Supreme Court recently ruled the penalty for violating the “Report of Foreign Bank and Financial Accounts” (FBAR) rules applies on a per-report basis, rather than a per-account basis. This decision brings clarity to a previously divided area of law, as the Fifth Circuit