FBAR UPDATE: The Sixth Circuit Rules Willfulness Includes Recklessness – March 2024
Background Under the Bank Secrecy Act, individuals with foreign bank accounts containing an aggregate of $10,000 or more must annually file a Report of Foreign Bank and Financial Accounts (“FBAR”) with the U.S. Department of the Treasury. An individual who fails to file an FBAR by the deadline risks civil penalties. If the failure to […]