A federal jury found that Carl Zwerner must pay more than $2 million for wilfully failing to file Reports of Foreign Bank and Financial Accounts (FBARs). In this case, the IRS sought a 50 percent penalty for each of the four years at issue, for a total of 200 percent in a civil case. Clearly, the punishment for not coming forward and reporting offshore accounts is pricey. In this case, the highest value of the account over the four years was approximately $1.55 million, but the total penalties for failing to file this report, which carries no tax, were approximately $2.24 million.
For more information, read the DOJ Press Release.