SCOTUS' Bittner Decision. How A $40,000 Non-Willful FBAR Penalty Can Be Considered a Win

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Ah...another day of "justice" meted out by our Supreme Court The government agrees the taxpayer did nothing intentionally wrong. But still wanted to impose $2.1 million in penalties -- for making an innocent mistake. Well thank goodness for the Supreme Court. They were able to muster the courage to get that down to $40,000.
The Bittner decision is a a victory of sorts - but only in relation to the complete hell the IRS insisted on imposing.
And no justices can apparently read the actual authorizing stature. If they did they would while there an FBAR regulations to be sure, there is no statute authorizing anything close to the FBAR.
So the question when will Yale and Harvard begin teaching its precious law school students remedial reading comprehension? It seems some basic instruction is sorely needed.
Host Attorney Anthony E. Parent, Esq. discusses fellow FBAR lawyer's John Richardson's latest article on the Bittner decision. He exposes why it might not be the victory people think. Joining them is Keith Redmond, Global Advocate for the American overseas. The three agree to the IRS's response - willful penalties.
citizenshipsol...
John RICHARDSON
www.citizenshipsolutions.ca
[e-mail]
If you want to remain a US citizen but lessen the impact of US taxation, the best time to get a tax plan together is now. Contact Anthony to help you.
Anthony PARENT
www.irsmedic.com
[e-mail]
If you aren’t sure what to do but don’t want to be forced into something that isn’t right for you, the best time to reach out to Keith Redmond is now. Contact Keith to help you.
Keith REDMOND
/ americanexpatriates
[e-mail]

[@mikebreen2890]

My own wife was in charge of making sure no US citizen got past first base when hiring in Prague, this after the company learned the hard way, in Belgium, that US citizens are a whole bunch of trouble.

[@UK-Property-Tax-Accountants]

Naples, Florida. My home town 🎉

[@HyperspaceHoliday]

I have a foreign account and the financial institution transferred the account to a different institution. It's the same account number but different company name and address and I now have no access to the old account at the previous institution, how do I report on this years FBAR? Do I need to mark as one account closed, then a new account(with the same number) opened? Or do I just list the account same as last year's report except with a different financial institution name and address?
I had no say in the transfer of the account and neither did I sign any new account opening documents.

[@mikebreen2890]

Bit of a nightmare, but at least the potential penalties seem to have dropped. Somebody told me that FBAR was simple, but I have thought of several scenarios where people can easily be caught out and in come huge penalties. See an expert, should only cost you $500 an hour. 😞

[@fxgreek5490]

Confiscation is every other penalty imposed.

[@fxgreek5490]

One keeps their A$$ and their Money where they perceive. there is green grass.

[@balivillaphotographer7535]

As things are $40,000 vs $4.2 mill is definitely a better outcome.
But crazy about the Signatory Authority, hence why I had to separate from former foreign business partner.

[@fxgreek5490]

Why? R U Jesting?