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March 2, 2023
|2 min read
Non-Willful, Per-Form Penalties Suffer a Bittner Fate: Supreme Court Resolves FBAR Penalty Dispute
The Supreme Court has released its 5–4 decision in Bittner v. United States, No. 21-1195, holding that the Bank Secrecy Act’s penalty for non-willful failure to file a Report of Foreign Bank and Financial Accounts (FBAR) applies on a per-form basis—and not on a per-account basis, as argued by the government.
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.
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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.
