IRS Compliance & PenaltiesAnswered

After Bittner, is the non-willful FBAR penalty once per year or per account?

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rasmus_8a31new member
May 29, 2026 1,450 views 1 answer
fbarbittnernon-willfulper-reportfincen-114

I had four foreign accounts under my LLC and missed FBARs for two years. Before, I read the penalty could be per account, which terrified me. Did the Bittner decision change that? If I had four accounts, is the non-willful penalty four times bigger, and what is the current dollar ceiling?

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