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Glossary entry · case law

Bittner

United States v. Bittner, 598 U.S. 85 (2023). Held 5-4 that the non-willful FBAR penalty is per annual form, not per account. Willful penalties remain per-account at the greater of $165,353 (2025-adjusted) or 50% of the balance.

Canonical reference

United States v. Bittner, 598 U.S. 85 (2023) — read the slip opinion. The penalty math + practitioner workflow implications are at AI for FBAR compliance.