Little noticed last month – around two weeks before the U.S. Supreme Court's landmark ruling on Feb. 28 on how penalties for "non-willful" Report of Foreign Bank and Financial Accounts (FBAR) violations should be determined – a U.S. District Court in California issued another major ruling involving FBARs.

Back in the 1960s, before Richard Nixon became U.S. president (in 1969), few "ordinary" Americans who lived abroad gave much, if any, thought to filing U.S. tax returns, let alone Foreign Bank Account Reports. Nor did the U.S. government seem much interested in finding out whether such expats might have overseas bank accounts, unless these expats were known to be wealthy.

(...or possibly not...)

Regular watchers of the way U.S. officials have been prosecuting American taxpayers whom they deemed to have committed "non-willful" breaches of the government's so-called FBAR regulations didn't have to be asked twice for their thoughts on Tuesday's landmark U.S. Supreme Court decision that – at long last – finally established how penalties for such breaches are to be determined. 

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.

The announcement in June that the U.S. Supreme Court had at last agreed to consider a case involving Foreign Bank Account Reports has been welcomed around the world by American expats, tax lawyers and others, many of whom had argued that the court's involvement was long overdue. 

...citing disproportionate penalties, pan-EU capital movement infringement 

Europe's top court has ruled against Spain's Modelo 720 "foreign asset law", declaring that its disproportionate penalties and potentially restrictive effects on the free movement of capital and payments across EU borders were violations of European regulations. 

Foreign Bank Account Report-watchers have long wondered when an FBAR case would finally reach the Supreme Court, and in so doing, at last begin settling questions having to do with the scope of FBAR penalties, which can be draconian.

But as Monday's Supreme Court announcement denying Alice Kimble the writ of certiorari that she had petitioned for back in June showed, the wait for the great, long-awaited FBAR showdown is set to run a little longer than some might have hoped it  would...

The last few weeks have seen the price of Bitcoin soar, accompanied by a roar of commentary from those who see it, and other cryptocurrencies, as the future.  

This latest round of Bitcoin mania was kicked off earlier this month, when (Bitcoin fan) Elon Musk's car company, Tesla, announced in an SEC filing that it had bought US$1.5bn worth of the cryptocurrency, and that it would also begin accepting Bitcoin in payment for its products...