The U.S Supreme Court Ruling on FBAR Penalty Payment – Bittner v. United States
On February 28th 2023, the Supreme Court ruled on Bittner v. The United States, a case brought forward by businessman Alexandru Bittner on the issue of how FBAR penalty payments ought to be calculated. The Supreme Court ruled that the penalty will be calculated on a per-report, and not on a per account, basis. […]
Swiss Bank Credit Suisse Accused Of Helping Clients Avoid U.S Tax
It was a decade ago that the scandal showing the Swiss bank Credit Suisse had been helping U.S citizens dodge tax first emerged. The bank pleaded guilty to hiding offshore assets and income on behalf of its American customers in 2014. The case culminated in a plea deal, in which the bank agreed to introduce […]
Fairbank v. Commissioner: The Role of the Statute of Limitations in Tax Law
In February 2023, a case against the Commissioner of Internal Revenue filed by a group of taxpayers was lost. Fairbank v. Commissioner was filed on behalf of a group of taxpayers who had been served a note of deficiency in 2018 on behalf of the years 2003-2009, and 2011 by the Internal Revenue Service. Their […]
Bittner v. United States Reaches Conclusion At The Supreme Court
On February 28th, 2023, the Supreme Court declared that the $10,000 amount specified in the Bank Secretary Act as a penalty for non-wilful misreporting of foreign interests in an FBAR document must be applied on a per report, not on a per-account, basis. This choice holds great significance, not in the least a fiscal one. […]
History’s greatest non-wilful FBAR penalty cleared by courts
Case Background At the center of the case involving the largest non-wilful FBAR penalty ever imposed by American courts is Alexandru Bittner. The Romanian-American businessman is a dual citizen, but in the year 1990, he left the US and relocated to his birth country of Romania. While in Romania, Bittner’s business ventures became profitable, resulting […]