Few recent U.S. Supreme Court rulings have hit American expat taxpayers, and the experts who advise them on tax matters, as powerfully as last Tuesday's decision in a long-running FBAR case involving a "non-willful" dual citizen named Alexandru Bittner.

In what is being seen as a major victory for Americans with non-U.S. bank accounts that they've failed to report to U.S. officials, the U.S. Supreme Court today ruled that the US$10,000 maximum penalty for such non-disclosure, if it's found to have been "non-willful," is to be applied on a per-form basis, and not per account.

Tomorrow – Nov. 2nd – the U.S. Supreme Court will begin to hear arguments in a closely-watched case that's expected to result in clarification, at last, as to how the penalties in so-called "non-willful Foreign Bank Account Report (FBAR)" cases should be determined.

Nov. 2nd has been set as the date when the U.S. Supreme Court will begin to hear arguments in a closely-watched case that's expected to result in clarification, at last, as to how the penalties in so-called "non-willful foreign bank account report (FBAR)" cases should be determined.

Alexandru Bittner, who has been one of the most visible challengers of the United States' notoriously persecutory FBAR penalty regime in recent years, has now become the latest FBAR litigant to urge the U.S. Supreme Court to rule, once and for all, on the way non-willful FBAR penalties should be determined.