Many Canadians own US-situs real estate, whether it is in New York, Florida, California or elsewhere in the US. It is often a surprise (or a “trap for the unwary”) to Canadian clients (or for that matter, any non-US client)...more
On February 28, 2023, in a significant tax case, Bittner v. US, the U.S. Supreme Court held that a U.S. person who fails to file his or her FBAR on a non-willful basis only is subject to a single penalty on the failure to...more
This fall, the Supreme Court is set to hear an important case regarding the interpretation of the law that provides for penalties for failing to file an FBAR. The case will impact many taxpayers who have already been...more