Supreme Court FBAR Hearing November 2, 2022: ALEXANDRU BITTNER, Petitioner, v. No. 21-1195 UNITED STATES, Respondent
Manage episode 345983572 series 3071154
On November 2, 2022 the Supreme Court Of The United States heard the Bittner case. The issue was whether in the context of a non-willful FBAR penalty:
1) The government is restricted to imposing one penalty based on the failure to file one FBAR; or
2) The government may impose one non-willful penalty for each of the accounts that should have been reported on the single FBAR form.
This podcast contains the audio file of the live arguments.
A transcript of the arguments is here:
http://citizenshipsolutions.ca/wp-content/uploads/2022/11/21-1195_5i36.pdf
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The FBAR penalties imposed on Mr. Bittner were based on years when he was a US citizen living outside the United States in Romania. Therefore, this decision is hugely important for the community of Americans abroad.
I have previously discussed the Bittner case in podcasts with:
Virginia La Torre Jeker - October 31, 2022
Jimmy Sexton - November 1, 2022
Anthony Parent - November 1, 2022
The following twitter thread reflects my impressions while listening to the arguments ...
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