The 4th District Federal Court has just held that there is willful failure to file an FBAR (TDF 90-22.1) form when you check the box "NO" on schedule B with reference to foreign bank and finanical accounts when you know you have combined highest balances in foreign accounts of $10,000 or more during the year. They stated this is sufficient showing of willfulness whether or not you know the FBAR (TDF 90-22.1) existed or was required to be filed.
If you willfully fail to file an FBAR form the penalties can be the greater of $100,000 or 50% of the highest balance in your accounts for each year. There are also criminal penalties for willful failure to file of up to five years in Jail and a $250,000 fine.
The penalties for non-willful failure to file the Form can be $10,000 or less.
If you willfully fail to file an FBAR form the penalties can be the greater of $100,000 or 50% of the highest balance in your accounts for each year. There are also criminal penalties for willful failure to file of up to five years in Jail and a $250,000 fine.
The penalties for non-willful failure to file the Form can be $10,000 or less.
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