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Peti-tioner Alexandru Bittner—a dual citizen of Romania and the United States—learned of his BSA reporting obligations after he returned to the United States from Romania in 2011, and he subsequently submit-ted the required annual reports covering five years (2007 through 2011).
Oct 31, 2022 · Because each violation bears a maximum penalty of $10,000, the difference for petitioner Alexandru Bittner is between a fine of $50,000 (for five years of delinquent reporting) or $2.72 million (for the 272 omissions from those five reports).
Mar 21, 2023 · The US Supreme Court in a close 5-4 decision issued on February 28, 2023 held that penalties for non-willful violations of FBAR filing requirements are to be assessed on a “per report” rather than a “per account” basis as contended by the IRS.
Feb 28, 2023 · On February 28, 2023, the U.S. Supreme Court decided Bittner v. United States, No. 21-1195, holding that the Bank Secrecy Act (BSA) treats the failure to file a legally compliant report as one violation carrying a maximum penalty of $10,000, regardless of how many bank accounts are at issue.
Facts. Petitioner Alexandru Bittner is a dual citizen of Romania and the United States. Bittner emigrated to the United States in 1982, where he obtained his American citizenship and lived until 1990, when he moved back to Romania.
Feb 28, 2023 · Petitioner Alexandru Bittner—a dual citizen of Romania and the United States—learned of his BSA reporting obligations after he returned to the United States from Romania in 2011, and he subsequently submitted the required annual reports covering five years (2007 through 2011).
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Party name: Alexandru Bittner: Attorneys for Respondent: Elizabeth B. Prelogar Counsel of Record: Solicitor General United States Department of Justice 950 Pennsylvania Avenue, NW Washington, DC 20530-0001: 202-514-2217: Party name: United States: Other: Caroline DeLisle Ciraolo Counsel of Record: Kostelanetz & Fink, LLP 601 New Jersey Avenue ...
