Foreign Account Penalty Lawsuits Loom After SCOTUS IRS Ruling

Following a Supreme Court ruling that the IRS has been over-penalizing people for non-willfully failing to report their foreign accounts, practitioners are hoping courts will further curb the IRS penalties in both willful and non-willful cases.

In a 5-4 ruling Tuesday, the high court agreed with Romanian-American businessman Alexandru Bittner that the IRS should have hit him with just five $10,000 penalties for his five years of non-willful reporting failures, rather than the 272 penalties it imposed—one for each unreported account in each of the five ...