There have been a number of recent court cases involving foreign bank account or FBAR reporting penalties. This is likely due to the significant amount of the penalty and that many do not fully appreciate the amount of the liability they face if caugh…
It is not clear as to what level of conduct justifies the imposition of the $100,000+ foreign bank account reporting (“FBAR”) civil tax penalty. In Bedrosian v. United States, No. 15-5853 (E.D. Pa. 2017), the court considered whether reckless conduct is sufficient given the facts presented in the case. The FBAR Civil Tax Penalty The […]
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