Shifting Currents in FBAR Penalties: A review of recent decisions.

The article discusses several court cases relating to foreign bank and financial accounts (FBAR)-related tax penalties in the U.S. These cases include Bittner v. United States which involved challenging the FBAR penalty under the Bank Secrecy Act, Aroeste v. U.S. wherein the court ruled over a dual resident under the provisions of an income tax treaty, and U.S. v. Saydam wherein the court ruled on whether a taxpayer's failure to file the FBAR timely was willful.