In Bittner v United States, SCOTUS settled the question of the appropriate method of calculating strict liability penalties for the failure to timely disclose reportable accounts on an FBAR.
Forbes contributors publish independent expert analyses and insights. Matthew F. Erskine is a trusts and estates attorney. In an era of increasing scrutiny on offshore accounts, the U.S. government ...
In September 2008, the IRS website posted revisions to the Report of Foreign Bank and Financial Accounts (Form TD F 90-22.1) that surprised many practitioners. This article discusses new traps for the ...