Opinion: Post-Bittner, might taxpayers who paid 'non-willful' FBAR penalties based on the no. of accounts they held... get a refund?
As regular readers of the American Expat Financial News Journal will know, the U.S. Supreme Court on Feb. 28 finally ended years of confusion over a major expatriate banking issue, when it found that a lower court – like so many others in the years leading up to this decision – had erred when it ruled in favor of an IRS policy of basing the penalties it assigned to Americans found to have "non-willfully" held numerous unreported overseas financial accounts on the numbers of such accounts they held.
