Court Orders That Individual Must Repatriate $18+ million From Switzerland to Pay Willful FBAR Penalty Liability
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Court Orders That Individual Must Repatriate $18+ million From Switzerland to Pay Willful FBAR Penalty Liability

ByJustin Hughes

On Tuesday October 26, 2021, Judge Bloom for the District Court of the Northern District of Florida adopted a Magistrate’s recommendation to issue an order to compel repatriation of funds to satisfy a willful FBAR penalty and accrued interest of more than $18 million dollars.[1] The Magistrate’s Report and Recommendation was issued on June 30,…

Taxpayer Wins District Court Case on Calculation of Non-Willful FBAR Penalties

ByJustin Hughes

In U.S. v. Bittner [1](available here: link), the U.S. District Court for the Eastern District of Texas (the “Court”) handed taxpayers a victory by declining to follow the legal analysis in Boyd v U.S.   In doing so the Court rejected the IRS’s interpretation of what constitutes a “violation” for purposes of computing non-willful FBAR penalties…