Insights & News

Supreme Court Decision Reduces FBAR Fine

March 08, 2023

Supreme Court Decides To Reduce FBAR Fine
The U.S. Supreme Court decided to throw out a $2.72 million fine on a Romanian-American businessman who failed to file Foreign Bank and Financial Accounts (FBAR) reports while living abroad. The taxpayer contended that the maximum penalty under federal law is $50,000. The IRS argued that the person violated the law 272 times, once for each account that was not reported in each of the five years. The Supreme Court held for the taxpayer, in a 5-4 vote, writing “that the failure to file a legally compliant report as one violation carrying a maximum penalty of $10,000, not a cascade of such penalties calculated on a per-account basis.”

Senate Democrats Push for Disclosure of Country-by-Country Tax Information
Senate Democrats reintroduced a bill that would force large multinational companies to reveal in their financial statements country-by-country information on business details that include profits, taxes and tangible assets. The bill’s disclosure requirements are expected to prevent companies from holding assets in low-tax jurisdictions. The bill came ahead of the Financial Accounting Standard Board’s proposal that will demand companies to disclose more tax details in the financial statements, including tax obligations by major jurisdictions.

Philadelphia DOR Issues FAQs About Tax Resolution Process
The Philadelphia Department of Revenue (DOR) issued frequently asked questions about the dispute resolution process of the Tax Review Board regarding tax assessments for property, corporate income, individual income, sales and use, excise and trust income tax purposes. The FAQs include the procedure for filing an appeal with the board. Also, the process after the appeal is filed and the procedure to follow if the taxpayer disagrees with the board’s decision is included.

Information contained in this publication should not be construed as legal advice or opinion or as a substitute for the advice of counsel. The articles by these authors may have first appeared in other publications. The content provided is for educational and informational purposes for the use of clients and others who may be interested in the subject matter. We recommend that readers seek specific advice from counsel about particular matters of interest.

Copyright © 2023 Stradley Ronon Stevens & Young, LLP. All rights reserved.

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