Settlement Calculus Shifts as SCOTUS Grants Foreign Account Case

The Supreme Court’s decision to review how the IRS assesses foreign bank account reporting penalties has shifted the decision-making for some account holders in settlement talks with the agency.

The high court agreed June 21 to take up United States v. Bittner, in which dual US-Romanian citizen Alexandru Bittner is arguing he only should have been assessed $10,000 for each year he didn’t submit an “FBAR” filing to report foreign bank and financial accounts. The government insists the $10,000 non-willful penalty applies to each account that isn’t reported, in each year of non-reporting.

The difference in penalty ...