The 5th Circuit Court of Appeals reversed a district court ruling stating the $10,000 penalty for non-willful failure to report a foreign bank account is per account and not per FBAR filing. The 9th circuit came to a different conclusion in 2021 stating that the penalty is per FBAR filing and not per account. This has far reaching implications for individuals with multiple accounts. As these two cases are recent this will likely be decided at the Supreme Court level in the near future on appeal. We will keep a close eye on the developments with this case.
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