Alexandru Bittner, Petitioner v. United States

  1. August 17, 2022

    Justices Urged To Choose Per-Year Cap On FBAR Penalties

    Administering trusts and estates could become chaotic if the U.S. Supreme Court rules that Congress intended the maximum penalty for failing to report a foreign account is $10,000 per account instead of per year, a trust group told the court.

  2. August 04, 2022

    Justices Set Nov. Date To Hear Arguments On FBAR Penalties

    The U.S. Supreme Court is set to hear oral arguments Nov. 2 in a case that could decide the limits of the $10,000 penalty for failing to disclose foreign bank accounts to the Internal Revenue Service.

  3. July 15, 2022

    International Tax Cases To Watch In The Second Half Of 2022

    Tax practitioners will have several high-stakes cases to track during the second half of 2022, including disputes brought by major U.S. multinational corporations that have accused the federal government of overstepping when writing regulations and reallocating foreign profits. Here, Law360 looks at eight key international tax cases to follow during the second half of 2022.

  4. June 21, 2022

    Justices To Weigh Foreign Account Tax Penalty Limits

    The U.S. Supreme Court decided Tuesday to hear a dispute over the maximum penalty for failing to disclose foreign bank accounts to the IRS in a case that could resolve the limits of a $10,000 penalty for undeclared accounts.

  5. May 18, 2022

    US Asks Justices To Weigh In On FBAR Max Penalty Dispute

    The federal government urged the U.S. Supreme Court to clear up a circuit split over the maximum assessable foreign bank account reporting penalty, arguing the $10,000 penalty should be imposed on a per-account basis rather than for each unfiled form.

  6. April 04, 2022

    Tax, Biz Groups Urge Justices To Review FBAR Penalty Suit

    Whether a foreign bank account reporting penalty is assessed per unreported account or per unfiled form should be determined by the U.S. Supreme Court, tax and business groups said, arguing a circuit split on the issue warrants high court intervention.

  7. March 03, 2022

    Justices Urged To Settle Max Penalty For FBAR Violations

    The U.S. Supreme Court should determine whether the $10,000 maximum penalty for unintentionally failing to timely report foreign accounts is assessed for each account or each form, as two appeals courts have arrived at divergent conclusions, a Texas man said.