On 21 June 2022, the United States (US) Supreme Court agreed to hear Bittner v. United States, a Fifth Circuit case on applying non-willful penalties for failure to report foreign financial accounts on FinCEN Form 114, otherwise known as an “FBAR” filing. Specifically, the Court will address whether the US$10,000 penalty¹ (as adjusted for inflation) imposed under 31 USC Section 5321 for non-w…