Introduction: Looking For Mr. FBAR – Outside Looking In Rather Than Inside Looking Out
FBAR cases are newsworthy. For the last decade blogs and legal journals have been populated by some of the most important FBAR questions of the day.
These questions (most of which are unresolved) include:
– What does willfulness mean in the context of the failure to file an FBAR? What if an individual incorrectly answers the FBAR question on Schedule B?
– What accounts are required to be reported? Gambling accounts? Crypto currency accounts? Gift card balances?
– What does “reasonable cause” mean and when can reasonable cause apply?
– and most recently: Can the Government impose a separate penalty on each unreported account or can only one penalty be reported based on the requirement of one FBAR form?