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Tag: Caroline Rule

Supreme Court Issues Groundbreaking Decision on FBAR Penalties

On February 28, 2023, the U.S. Supreme Court issued a groundbreaking decision in the case of Alexandru Bittner v. United States (No. 21-1195), holding that the penalty for a non-willful failure to file a Report of Foreign Bank and Financial Accounts (FBAR) applies on a per-report basis, and not on

U.S. Supreme Court Agrees to Review Major FBAR Penalties Case

On June 21, 2022, the U.S. Supreme Court agreed to hear a major case regarding IRS penalties relating to Reports of Foreign Bank and Financial Accounts (FBARs). Kostelanetz & Fink represents the American College of Tax Counsel (the “College”), which filed an amicus brief in Alexandru Bittner v. United States