In recent years, the government has made concerted efforts to win willful FBAR penalty cases through summary judgment motions. This is not surprising. Thus far, it has convinced courts that ...

Addressing claim construction, enablement, damages and willfulness, the US Court of Appeals for the Federal Circuit found that evidence of a defendant’s knowledge of the asserted patent and proof of ...

The concept of “willfulness” is an important one in the FBAR civil penalty context. Indeed, a taxpayer’s willful failure to file a timely and accurate FBAR may result in significant penalties: the ...