There has been a lot of discussion about the possible U.S. tax obligations for Pope Leo XIV, the first U.S. citizen Pope. Some of the assertions have generated confusion, leaving key U.S. tax concepts ...

A Report of Foreign Bank and Financial Accounts must be filed by a U.S person with financial interests in or authority over certain foreign accounts. If you’re a U.S. citizen living abroad, it ...

On Feb. 28, 2023, the U.S. Supreme Court issued its opinion in Bittner v. United States, which focused on the correct penalty amount for non-willful violations of the foreign bank and financial ...

Cross-border clients who aren’t caught up on their foreign-account tax filings in the U.S. can breathe a small sigh of relief, but should aim to comply as soon as possible. The U.S. Supreme Court ...

On Nov. 2, 2022, the U.S. Supreme Court will hear oral argument in Bittner v. United States. The case will decide how the penalty for failing to timely file a Foreign Bank Account Report (FBAR) is ...

In Boyd, the taxpayer first disclosed her interest in several financial accounts located in the United Kingdom in connection with her participation in the IRS's 2012 Offshore Voluntary Disclosure ...

The Supreme Court has docketed Bittner v. U.S. for its fall calendar, setting it to resolve a split between the Fifth Circuit and the Ninth Circuit on the penalty for violation of the Report of ...

The United States Department of Treasury is again sharpening its sword upon crypto. In January 2021, the Department of Treasury’s Financial Crimes Enforcement Network issued Notice 2020-2. The Notice ...

A federal district court has sided with the taxpayer on an FBAR penalty issue, reducing the amount owed by the 89-year-old taxpayer from $160,000 to $40,000. At issue in the case, U.S. v. Giraldi, was ...