In United States v. Boyd, No. 19-55585 (9th Cir. Mar. 24, 2021), the U.S. Court of Appeals for the Ninth Circuit, in a case of first impression for the circuit, held that the IRS is limited to imposing one penalty for the untimely filing of a single accurate “Report of Foreign Bank and Financial Accounts” (FBAR) that includes multiple foreign accounts.
Posted by Lewis J. Saret, Co-General Editor, Wealth Strategies Journal..