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Taxpayer B has 5 accounts, each with $50,000. IRS asserts the maximum willful penalty, which is the greater of $100,000 or 50% of the balance. That penalty comes out to $125,000. Taxpayer B's FBAR penalty for willful failures to file is less than Taxpayer A's non-willful penalties.An FBAR non-willful penalty is a “lower-level” penalty for not filing the FBAR. The non-willful penalties can be high, BUT, typically they are not as high as willful penalties. Willful FBAR Penalties and (Reduced) Willfulness. The Willful FBAR Penalty is typically more severe. An FBAR Willful Penalty is penalty for acting willful, willfully ...
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