


Michele Weiss Analyzes Effects of U.S. Supreme Court’s FBAR Opinion in Bittner v. U.S. for Beverly Hills Bar Association Webinar
Michele Weiss, Principal at Holtz, Slavett & Drabkin, will participate in a Beverly Hills Bar Association panel exploring how to navigate the new landscape for Foreign Bank Account Report (FBAR) penalties in light of the U.S. Supreme Court decision in Bittner v....
Are FBAR Penalties Limited? U.S. Supreme Court Will Decide.
On June 21, 2022, the U.S. Supreme Court decided to review (that is, granted certiorari) in the case of Bittner v. United States. This case centers around the report of foreign bank and financial accounts (FBAR) and penalties for not timely filing the FBAR form. The...
Can Non-Willful FBAR Penalties Exceed $10,000 Per Year?
by Michele Weiss US taxpayers are obligated to file a foreign bank account report (“FBAR”) if the aggregate value of their foreign account interests exceeds $10,000 on any day during a calendar year. 31 U.S.C. § 5314; 31 C.F.R. §§ 1010.350(a), 1010.306(c). Taxpayers...
Recent FBAR Cases Show Mixed Results in Taxpayers Fighting Against Aggressive Penalties
Crackdown on the offshore accounts continues to be one of the top priority issues for the IRS. In the last few years, the DOJ and the IRS have taken aggressive positions in imposing and collecting huge penalties for taxpayers’ failure to report their foreign accounts...
IRS implements new COVID-19 Initiative to Assist Taxpayers
IRS temporarily adjusts and suspends key compliance programs to help people facing the challenges of COVID-19 issues.