Foreign financial reporting is no longer just about Swiss bank accounts. Today, U.S. taxpayers may have foreign brokerage accounts, international retirement plans, and cryptocurrency held on offshore exchanges — all of which can trigger complex reporting obligations under FBAR and FATCA. While many taxpayers assume these filings are minor disclosures, recent court cases make clear that the penalties for late or missing FBAR filings can be significant — even when no tax was ow

What happens when the IRS acts as prosecutor, jury, and judge—all at once? That’s the question at the heart of the United States v. Sagoo case (2025), a landmark court decision that could reshape how international tax penalties are assessed.