Calculating a willful FBAR penalty

Calculating a willful FBAR penalty



The purpose of the FBAR form was to give Treasury an E-Z way to penalize
the worst of the worst. But the worst of the worst, if they read the
law carefully can avoid having a foreign account with any balance
subject to an willful FBAR non-filing. You see, 50% of $0 = $0 Sure,
there are a whole bunch of other laws being broken, but isn't the entire
rationale for requiring self-reporting of foreign bank account
completely undermined?