In previous blogs, Freeman Law discussed recent federal cases related to 31 U.S.C. § 5321—specifically, whether Section 5321 authorizes the IRS to impose multiple non-willful penalties for the untimely filing of a single accurate FBAR that includes multiple foreign accounts. In United States v. Bittner,[1] the District Court for the Eastern District of Texas held for the taxpayer (i.e., non-willful FBAR penalties should be assessed on a per-reporting basis, not a per-account basis). For more information, see the following Insight Blogs: The Largest Non-Willful FBAR Penalty Case Ever? and Court Strikes Down Largest Non-Willful FBAR Penalty Ever. Now, that case is currently pending with the Fifth Circuit Court of Appeals.
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