Bloomberg Tax
March 24, 2021, 4:59 PMUpdated: March 24, 2021, 6:22 PM

Only One Non-Willful Penalty for FBAR Breach, Court Says (2)

Aysha Bagchi
Aysha Bagchi

The IRS may impose only one non-willful penalty for filing a late but accurate report of foreign bank accounts, regardless of the number of accounts involved, the Ninth Circuit ruled.

The Wednesday decision reversed a district court’s ruling and garnered the dissent of one of the three judges on the U.S. Court of Appeals for the Ninth Circuit panel. The case arose after the IRS imposed multiple penalties totaling $47,279 against U.S. citizen Jane Boyd for failing to timely file a required Report of Foreign Bank and Financial Accounts form (FBAR) to disclose her financial interest in ...