Tax Impacts
Sort by:
2 results
December 27, 2021
|6 min read
FinCEN Amends Willful FBAR Regulations
On December 23, 2021, the United States (“U.S.”) Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) announced amendments to the Bank Secrecy Act (“BSA”) penalty regulations to remove certain civil penalty language (previously, 31 C.F.R. § 1010.820(g)), despite FinCEN’s previous failure to modify the regulations after the enactment of the American Jobs Creation Act of 2004 (“American Jobs Creation Act”), Pub. L. No. 108-357, § 821, 118 Stat. 1418 (2004).
December 3, 2021
|1 min read
Fifth Circuit Holds that Non-willful FBAR Penalties Apply on Per-Account Basis
On November 30, 2021, the Fifth Circuit Court of Appeals in U.S. v. Bittner, __ F.4th __ (5th Cir. Nov. 30, 2021), held that penalties for non-willful failures to report foreign bank accounts apply to each unreported bank account as opposed to each report not filed, as held by other courts.
About This Blog
Winston & Strawn’s Tax Impacts series features timely updates and insights impacting taxpayers, spanning from federal, international, and state and local tax planning to controversy.
