Jack Townsend (Federal Tax Crimes Blog) : District Court holds (1) FBAR Penalty Statute of Limitations is Waivable and (2) FBAR Nonwillful Penalty is Per Account (November 8, 2021)

Jack Townsend, of the Federal Tax Crimes Blog, has made available for download his article, “District Court holds (1) FBAR Penalty Statute of Limitations is Waivable and (2) FBAR Nonwillful Penalty is Per Account,” published in the Federal Tax Crimes Blog. The abstract is as follows:

The Court’s analysis is comprehensive and well-reasoned, adopting in part Judge Ikuta’s dissent in Boyd.  (That is not to say that the court’s conclusion is right, for I think the issue is the type of issue that really can go either way; as I view these “go either way” issues, they proceed in search of a consensus (either in the courts or by statutory amendment) so that similarly situated citizens at some point get treated similarly but until consensus is reached, it is messy.)  

Click here to view Jack Townsend’s full summary of “District Court holds (1) FBAR Penalty Statute of Limitations is Waivable and (2) FBAR Nonwillful Penalty is Per Account”.

Posted by Isabella King, Associate Editor, Wealth Strategies Journal.