Penalty for failing to report interests in foreign financial accounts.
AJCA Section 821 amends 31 USC Section 5321 to add an additional civil penalty that may be imposed without regard to willfulness on persons who violate the reporting requirement applicable to an account with a foreign financial entity. The penalty is capped at $10,000 (with willful violations subject to penalties of up to $100,000).
The provision is effective for violations occurring after Oct. 22, 2004.
FROM PAUL MANNING, WASHINGTON, DC
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|Publication:||The Tax Adviser|
|Date:||Jan 1, 2005|
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