Supreme Court Rules In Taxpayer's Favor On FBAR Penalties

Today, February 28, 2023, the Supreme Court held that the Bank Secrecy Act's $10,000 maximum penalty for the non-willful failure to file a compliant report should be calculated per report, not per account. The opinion notes, 'Best read, the BSA treats the failure to file a legally compliant report as one violation carrying a maximum penalty of $10,000, not a cascade of such penalties calculated on a per-account basis.' See: Supreme Court Rules In Taxpayer’s Favor On FBAR Penalties (


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