Experts say refusal to hear case raises questions as to
whether civil penalties might ever be deemed
to violate Eighth Amendment...

In the latest in a series of cases that experts say has potentially major repercussions for expatriate Americans, a U.S. District Court in California has ruled that the penalty for a so-called "non-willful" failure to file foreign bank account reports (FBARs) should be calculated on a "per-FBAR", annual form basis, rather than for each bank account held by the American taxpayer in question outside the U.S.

In a case experts say has potentially major repercussions for expatriate Americans, the U.S. District Court for the Eastern District of Texas has ruled that the penalty for so-called "non-willful violations" of the U.S. Foreign Bank Account Reporting regulations should be calculated on a "per-FBAR", rather than per account, basis.

The U.S. government may still be largely shut down, but non-U.S. resident Americans who have U.S. tax reporting obligations may now be able to kick off the 2018 reporting season by filing their 2018 Foreign Bank Account Reports, as the official FBAR exchange rates have just been published.