In a Sept. 26, 2022 article in the Law360 Tax Authority titled “Gov’t May Struggle to Justify FBAR Calculations At High Court,” tax professionals weighed in on “obstacles” the federal government may face “in trying to prove the $10,000 maximum penalty for a nonwillful failure to file a Report of Foreign Bank and Financial Accounts (FBAR) should be calculated per account as opposed to per year.” Partner Jeff Paravano told Law360 that “the courts should interpret the nonwillful FBAR statute in a way that favors taxpayers, because taxpayers ‘shouldn’t be surprised by penalties.’”
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