Little Red FBAR Book

The purpose of this page is to collect my posts about Mr. FBAR into “The Little Red FBAR Book”. These posts have been written over a number of years.

The organization will be to organize and places the posts into broader modules as follows:

Prologue: “Writing in 1948, George Orwell (in his book 1984) identified the need to identify and punish all things “foreign” as being important for domestic security.”

Will A Business Trip To The United States Triggers A Meeting With Mr. FBAR?

Module 1 – The History And Evolution Of The Statutory, Regulatory And Penalty Framework

Part 1: Mr. FBAR’s Civil Penalty – 5321(a)(5): Evolution – The Wonder Years, Those Teenaged Years, Young Adult, To Mature Thug
Part 2: Mr. FBAR’s Civil Penalty – 5321(a)(5): Interpreting The Penalty Provision – Asking The Right Questions
Part 3: Mr. FBAR’s Civil Penalty – 5321(a)(5): Schik – Willful Or Non-Willful And What Does Willful Even Mean?
Part 4: Mr. FBAR’s Civil Penalty – 5321(a)(5): Toth – Excessive Fine, Based On Willfulness Decreed By Sanction And Not Factual Determination
Part 5: Mr. FBAR’s Civil Penalty – 5321(a)(5): Bittner – Maximizing The Penalty By Imposing It On Each Account
Part 6: Mr. FBAR’s Civil Penalty – Does 31 USC 5321(a)(5) Authorize The Imposition Of ANY Civil Penalty For Failure To File An FBAR?

Module 2 – What The FBAR Regulation Requires Individuals To Do

Module 3 – When Do The Rules Require One To File An FBAR For Accounts You Don’t Own?

Module 4 – Penalties, Reasonable Cause And Penalty Abatement