Alexandru Bittner, Petitioner v. United States
Case Number:
21-1195
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July 07, 2023
Top International Tax Cases In 1st Half Of 2023
The Internal Revenue Service scored a victory early this year when a divided U.S. Tax Court upheld contested transfer pricing regulations, followed by a defeat in Tennessee, where a federal judge struck down rules for the 2017 tax overhaul’s repatriation provision. Here, Law360 breaks down major international tax decisions issued during the first half of 2023.
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July 03, 2023
Top Federal Tax Cases In 1st Half Of 2023
The Internal Revenue Service's authority to assess penalties tied to foreign information returns was the subject of notable federal tax decisions in the first half of 2023, while the U.S. Supreme Court maintained the agency's power to issue third-party summonses without prior notification. Here, Law360 reviews significant tax rulings by federal courts in the past six months.
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February 28, 2023
Justices Reject Higher Fines For Nonwillful FBAR Violations
The U.S. Supreme Court ruled Tuesday that the Bank Secrecy Act's $10,000 maximum penalty for the nonwillful failure to report foreign bank accounts applies per form and not for each account.
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January 02, 2023
Federal Tax Cases To Watch In 2023
In the coming year, the U.S. Supreme Court will hear multiple high-profile tax cases involving attorney-client privilege and foreign bank account penalties, while lower courts will continue to grapple with the legitimacy of IRS rulemaking. Here, Law360 reviews the top federal tax cases to watch in 2023.
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November 02, 2022
Justices Press Gov't To Justify How It Calculates FBAR Fines
The federal government's attempt to penalize a Texas man for unintentionally failing to report his foreign bank account information may prove problematic as the statute authorizing the penalty lacks specific language to levy the fine per undisclosed account, U.S. Supreme Court justices said Wednesday.
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October 24, 2022
US Incorrectly Calculates FBAR Penalties, Justices Told
Penalties for unintentionally failing to disclose foreign bank accounts to the Internal Revenue Service should be assessed for each unfiled form and not per unreported account, a Texas man facing $2.72 million in such penalties told the U.S. Supreme Court.
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October 07, 2022
Whistleblower Org Backs 5th Circ. FBAR Ruling At High Court
A whistleblower advocacy organization said the U.S. Supreme Court should affirm an appellate court decision supporting the government's method of penalizing taxpayers who fail to report their foreign bank accounts.
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October 03, 2022
US Properly Applies FBAR Penalty Per Account, Justices Told
A lower court correctly interpreted the law in allowing the Internal Revenue Service to impose nonwillful $10,000 penalties for each foreign bank account that a Texas man didn't properly disclose, the U.S. government told the U.S. Supreme Court.
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August 25, 2022
Justices Urged To Ax Harsher Foreign Account Tax Penalties
The U.S. Supreme Court should undo a decision that the IRS can assess penalties on each inadvertently undisclosed foreign account rather than taking the more lenient approach of assessing the penalty once annually, the U.S. Chamber of Commerce said Thursday.
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August 19, 2022
Supreme Court Asked To Limit FBAR Fines To 1 Per Year
The U.S. Supreme Court must rule that a $10,000 penalty for neglecting to report foreign bank accounts is calculated per year, not per account, a Texas man facing a $2.72 million fine told the court.