Note: There is no credit for the recording.
On January 11, 2021 the U.S. District Court in Connecticut decided USA v. Kaufman and held that the maximum penalty for unintentionally failing to file FBARs is $10,000 per year. Not $10,000 per account. This is a major victory for taxpayers as the IRS has sought to use the non-willful FBAR penalty to exact large penalties from taxpayers, many of whom did not even know they had foreign accounts, who made honest mistakes. Trial counsel for the taxpayer will discuss the impact of this case on FBAR litigation and provide an update of best practices for offshore compliance.
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