The Supreme Court And Mr. FBAR - Should The Non-willful Penalty Be Limited To The Form? - Discussion with @JimmySextonLLM

October 31, 2022 - Participants include:

 

John Richardson - @Expatriationlaw

Jimmy Sexton - @JimmySextonLLM

Should non- willful FBAR penalties be imposed for the failure to file the form (one penalty) or the failure to report each account on the form (multiple penalties)?

What is the purpose of the FBAR when it duplicates information that is included in Form 8938?

The court documents including the amicus briefs are here ...

https://www.supremecourt.gov/search.aspx?filename=/docket/docketfiles/html/public/21-1195.html