USA v. Bittner

  1. January 03, 2022

    International Tax Cases To Watch In 2022

    Courts will continue grappling this year with high-stakes cases brought by major U.S. multinationals that have accused federal tax authorities of overstepping, with disputes including FedEx's challenge to repatriation regulations and Facebook's fight against multibillion-dollar adjustments to its tax bill. Here, Law360 looks at eight key international tax cases to follow in 2022.

  2. November 30, 2021

    5th Circ. Says Max FBAR Penalty Applies To Each Account

    The Fifth Circuit ruled Tuesday that the $10,000 maximum penalty for a nonwillful failure to file a foreign bank account report applies to each account, not each year, reversing a lower court's decision and diverging from the Ninth Circuit.

  3. March 29, 2021

    Dual Citizen Must Face FBAR Tax Obligation, Gov't Argues

    A dual citizen's argument that he shouldn't be penalized for failing to timely report foreign assets because he had been unaware of his U.S. tax obligations can't excuse his not paying for several years, government attorneys told the Fifth Circuit.

  4. January 26, 2021

    Dual Citizen Didn't Know Of FBAR Obligations, 5th Circ. Told

    A Texas resident with citizenship in Romania shouldn't be liable for penalties after failing to timely report his foreign assets to the IRS because he was initially unaware of his U.S. tax obligations, he told the Fifth Circuit.