IRS FBAR Penalty Guidelines Suggest Lower Risk of Multiple “Per Account” and “Per Year” Penalties
Penalties for willful violations of FBAR filing requirements can be as high as 50% of the balance of the subject accounts EACH YEAR. Penalties for nonwillful violations can be as high as $10,000 PER UNREPORTED ACCOUNT per year. In a recently issued guidance memorandum, the IRS seeks to provide guidance to its personnel…