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    Whether you’re looking for fun and sun, a peaceful retirement, or the chance to earn some extra income, you’ve got a real world of opportunity open to you… In short, we’ve done our best to narrow down your best options, but only you can decide the right country for you.

    • Spain
    • Portugal
    • Panama
    • Belize
    • Colombia
    • Cyprus
    • Mexico
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    • Browse All Countries

    Best For:

    • The Best Places To Retire
    • Health Care Abroad
    • Cost Of Living
    • Investing in Real Estate
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    • Gun Laws In The World
    • English-Speaking Countries
    • Safest Places For Retirement
    • Best Places In Latin America
  • Budgets

    How Much Will It Cost You To Live Overseas?

    The only honest answer is, we have no idea. And neither does anyone else. The only one who can answer that question is you. Here’s the most important thing to understand about budgeting your new life overseas…

    Super Cheap

    • Chitré, Panama
    • Santa Marta, Colombia
    • Phuket, Thailand
    • Dumaguete, The Philippines

    Cheap

    • Medellin, Colombia
    • Boquete, Panama
    • Kyrenia, Cyprus
    • Hua Hin, Thailand
    • The Algarve, Portugal

    Affordable

    • Valencia, Spain
    • Cascais, Portugal
    • Las Terrenas, The DR
    • Pisa, Italy
    • La Rochelle, France
    • Mazatlán, Mexico

    Luxury

    • Ambergris Caye, Belize
    • Kotor, Montenegro
    • The Panama City Beaches
    • Paris, France
  • Resources

    Global Living

    • Living & Retiring Overseas
    • Raising A Family Abroad
    • Foreign Residency & Citizenship
    • Offshore & Diversification

    Making Money

    • International Real Estate
    • Banking
    • Employment
    • Investing

    Follow Us:

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    Buying Real Estate For Cashflow

    • Discover tips and strategies used by global property investing veterans

    Explore Our Latest Posts

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  • Home
  • Countries

    Top Destinations:

    Whether you’re looking for fun and sun, a peaceful retirement, or the chance to earn some extra income, you’ve got a real world of opportunity open to you… In short, we’ve done our best to narrow down your best options, but only you can decide the right country for you.

    • Spain
    • Portugal
    • Panama
    • Belize
    • Colombia
    • Cyprus
    • Mexico
    • France
    • Montenegro
    • Browse All Countries

    Best For:

    • The Best Places To Retire
    • Health Care Abroad
    • Cost Of Living
    • Investing in Real Estate
    • Establishing Residency
    • Gun Laws In The World
    • English-Speaking Countries
    • Safest Places For Retirement
    • Best Places In Latin America
  • Budgets

    How Much Will It Cost You To Live Overseas?

    The only honest answer is, we have no idea. And neither does anyone else. The only one who can answer that question is you. Here’s the most important thing to understand about budgeting your new life overseas…

    Super Cheap

    • Chitré, Panama
    • Santa Marta, Colombia
    • Phuket, Thailand
    • Dumaguete, The Philippines

    Cheap

    • Medellin, Colombia
    • Boquete, Panama
    • Kyrenia, Cyprus
    • Hua Hin, Thailand
    • The Algarve, Portugal

    Affordable

    • Valencia, Spain
    • Cascais, Portugal
    • Las Terrenas, The DR
    • Pisa, Italy
    • La Rochelle, France
    • Mazatlán, Mexico

    Luxury

    • Ambergris Caye, Belize
    • Kotor, Montenegro
    • The Panama City Beaches
    • Paris, France
  • Resources

    Global Living

    • Living & Retiring Overseas
    • Raising A Family Abroad
    • Foreign Residency & Citizenship
    • Offshore & Diversification

    Making Money

    • International Real Estate
    • Banking
    • Employment
    • Investing

    Follow Us:

    • Meet Our Experts
  • Real Estate

    Buying Real Estate For Cashflow

    • Discover tips and strategies used by global property investing veterans

    Explore Our Latest Posts

    • Learn how to invest and purchase property abroad…

    Go To The Overseas Property Alert Site

    • How To Become Independently Wealthy And Fund The Lifestyle Of Your Dreams
  • Conferences

    Upcoming Events

    • Explore Our Events Site

    Live and Invest In Spain Conference

    Offshore Wealth Summit

    Greece Workshop

    VALENCIA, SPAIN

    Sep. 17-19, 2025

    PANAMA CITY, PANAMA

    Oct. 15-17, 2025

    VIRTUAL

    Nov. 13, 2025

    Learn More About This Event
    Learn More About This Event
    PRE-REGISTER
    Learn More About This Event
    PRE-REGISTER
    • MORE EVENTS

    Contact Our Events Team

    Toll-Free U.S. and Canada:
    1 (888) 627 8834
    From Outside North America:
    1 (443) 599 1221
    Working Hours
    Monday – Friday 08:00 am – 17:00 pm EST.

    Reach us with your questions by email at: events@liveandinvestoverseas.com

  • Store

    Unlock The World

    • Access Your Library

    Overseas Havens Reports

    • Expats' comprehensive destination guides

    Conference Kits

    • Hours of coverage  from our latests conferences

    Lahardan Books

    • Titles on living and investing around the world
    • Explore Our Store
    Your passport to a life well-lived abroad

    Services

    overseas living letter offers affordable retirement guidance
    The Simon Letter Wealth Protection Insights
    Global Property Advisor Global Investment Opportunities

    Our Customer Service team is here to assist with any questions or concerns CustomerService@LiveandInvestOverseas.com

  • My Library
Live and Invest Overseas
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Home Taxes

Good News For Those Who File The FBAR

Justice Done

by Lief Simon
Mar 29, 2023
in Taxes
0 0
Money coins stack growing graph and piggy bank

Adobe Stock/N_studio

Do you file the FBAR? A few weeks ago, the United States Supreme Court handed down an important judgment… It didn’t make many headlines…

You won’t have seen it on the front page of most newspapers… unlike other controversial Supreme Court cases, like the Dobbs decision on abortion last year, or the case against the Biden administration’s student debt forgiveness scheme.

But, for American taxpayers who live and work overseas, the ruling in Bittner v. United States is a big deal…

The case involved one Alexandru Bittner, who holds both U.S. and Romanian citizenship.

He immigrated to the States in the 1980s and obtained U.S. citizenship, but moved back to Romania in 1990.

In the following two decades, Bittner made more than US$70 million from investments, including real estate and securities.

He held multiple foreign bank accounts… But as a U.S. citizen, he could not escape his U.S. tax obligations, even though he lived abroad (and held dual citizenship).

Now, this should set alarm bells going in your brain, dear reader.

Let’s say a U.S. person holds US$10,000 in a foreign bank account (or across multiple accounts) at any point during the calendar year, he’s required to report that money by filing an FBAR (Foreign Bank and Financial Accounts form)…

Failure to report can mean big penalties

Originally, the FBAR law (which dates to 1970) was only meant to penalize “willful” violations—in other words, if you purposefully do not report the account information.

But in 2004, Congress amended the law so it also included “non-willful” violations. So, you could be punished even if you only accidentally failed to report.

The penalty for willful failure to report is US$100,000, while a non-willful failure carries just a US$10,000 fine…

Bittner claimed not to know about the filing requirement and did not file any FBARs until 2012.

The IRS accepted that Bittner did not know about the filing requirements and therefore his violations were “non-willful.”

However, they still slapped a gigantic fine on him: a total of US$2,720,000.

This was a very simple calculation by the IRS: Bittner had made 272 separate violations of the law, since he failed to report 272 accounts between 2007 and 2011. (Bittner’s failures to file prior to 2007 were not counted, thanks to the statute of limitations.)

US$10,000 multiplied by 272 equals US$2.72 million.

Bittner objected (who wouldn’t) and took the case as far as the Supreme Court…

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Was It 5 Violations—Or 272?

Bittner argued that the penalty, as written in the law, applies to each failure to file an FBAR, not to each account…

So, even if he owned 177 foreign bank accounts (the number he admitted to) between 2007 and 2011, with more than US$10,000 in them… the number of accounts didn’t matter.

You only have to file one FBAR per year—not one per foreign bank account.

So, Bittner argued he should be penalized five times over—one for each year he failed to file an FBAR—not hundreds of times over, for each account he failed to report…

He argued, essentially, he should be punished for the five forms he failed to fill out, not the hundreds of accounts he failed to report…

Five times US$10,000 is of course a much smaller amount to have to pay…

Good News For Taxpayers (For Once)

In a 5 to 4 ruling on Feb. 28, the Supreme Court sided with Bittner: The US$10,000 penalty applies per failure to file an FBAR, not per foreign account.

So, American expat groups around the globe celebrated the decision…

It’s good news for people with offshore bank accounts… and really for all taxpayers, I think, as it’s a slap on the wrist for the IRS.

The IRS approach to raising money through excessive penalties isn’t on solid ground.

At a minimum, it’s a good thing for people who are simply unaware of the FBAR filing requirements who get caught up in these things…

My own personal view is that the IRS will decide from now on that all violations are “willful” and seek the maximum US$100,000 penalty.

But Alex Bittner just saved himself US$2.67 million by taking his fight to the highest court in the land…

Good for Alex.

Stay diversified,
Lief Simon signature
Lief Simon
Editor, Simon Letter

Tags: 'FBAR''Taxes'Americans Overseasfile fbarLive abroadTax
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Lief Simon

Lief Simon

Lief Simon has lived and worked in 7 countries on 5 continents and traveled to more than 75 countries. His real estate investment career began with a $5,000 down payment on a three-flat building in Chicago. Less than three years later, Lief sold the building for a leveraged return of 3,000%—$150,000 in profit after closing costs and commissions.

From there, he turned his attention overseas and has bought property in 24 countries including France, Croatia, Portugal, Ireland, Belize, Spain, Argentina, Cyprus, Romania, and beyond. Thanks to his decades-long career as a global property investor, Lief has built a multi-million-dollar portfolio that includes rental properties, significant land holdings, and 7 personal residences.

Lief has established residency in 3 countries and acquired a second passport from Ireland.

In 2008 Lief and wife Kathleen Peddicord made the most important investment of their lives—a 215-acre oceanside finca, known as Los Islotes. There, on Panama’s largely undiscovered Veraguas coast, they’ve installed underground electricity, water, and internet and built a forever family home that sits at the heart of their ultimate vision: a gold standard private residential community for those in search of a true safe haven escape.

Lief’s latest book, “Cowboy Millionaire—The New American Pioneer,” collects all the wisdom he has learned in three decades of living and investing outside America.

He offers advice on international diversification in his twice-weekly Offshore Living Letter and monthly Simon Letter dispatches. For real estate investment opportunities, check out his monthly Global Property Advisor service.

If you’d like to meet Lief in person, join him for one of our upcoming in-country conferences. You’ll find further details here.

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HOME

Top Countries

  • Spain
  • Portugal
  • Panama
  • Belize
  • Colombia
  • Cyprus
  • Mexico
  • France
  • Montenegro

Best For:

  • Health Care Abroad
  • Retirement Living
  • Cost Of Living
  • Investing in Real Estate
  • Establishing Residency
  • Gun Ownership
  • English Speakers
  • Safety
BROWSE ALL COUNTRIES

Budgets

How Much Will It Cost
To Live Overseas?

Super Cheap

  • Chitré, Panama
  • Santa Marta, Colombia
  • Phuket, Thailand
  • Dumaguete, The Philippines

Cheap

  • Medellin, Colombia
  • Boquete, Panama
  • Kyrenia, Cyprus
  • Hua Hin, Thailand
  • The Algarve, Portugal

Affordable

  • Valencia, Spain
  • Cascais, Portugal
  • Las Terrenas, The DR
  • Pisa, Italy
  • La Rochelle, France
  • Mazatlán, Mexico

Luxury

  • Ambergris Caye, Belize
  • Kotor, Montenegro
  • The Panama City Beaches
  • Paris, France

Resources

Global Living

  • Living & Retiring Overseas
  • Raising A Family Abroad
  • Foreign Residency & Citizenship
  • Offshore & Diversification

Making Money

  • International Real Estate
  • Banking
  • Employment
  • Investing
Meet Our Experts

Real Estate

Overseas Property Alert 

 

How To Become Independently Wealthy And Fund The Lifestyle Of Your Dreams

VISIT SITE

Buying Real Estate For Cashflow

 

Discover tips and strategies used by global property investing veterans

READ MORE

Explore Our Latest Posts

 

Learn how to invest and purchase property abroad…

EXPLORE

Conferences

Live and Invest In Spain Conference

VALENCIA, SPAIN Sep. 17-19, 2025
Learn More About This Event

Offshore Wealth Summit

PANAMA CITY, PANAMA Oct. 15-17, 2025
Learn More About This Event
PRE-REGISTER

GREECE WORKSHOP

VIRTUAL Nov. 13, 2025
Learn More About This Event
PRE-REGISTER
MORE EVENTS

Contact Our Events Team:

Toll-Free U.S. and Canada:
1 (888) 627 8834

From Outside North America:
1 (443) 599 1221

Working Hours
Monday – Friday 08:00 am – 17:00 pm EST.

Reach us with your questions by email at: events@liveandinvestoverseas.com

Store

Overseas Havens Reports

  • Expats' comprehensive destination guides

Conference Kits

  • Hours of coverage  from our latests conferences

Lahardan Books

  • Titles on living and investing around the world

Services

  • Overseas Living Letter: Affordable Retirement Guidance
  • The Simon Letter: Wealth Protection Insights
  • Global Property Advisor: Global Investment Opportunitites
VISIT OUR STORE

Free Report

THE 10 BEST PLACES TO RETIRE IN 2025

FREE REPORT: The 10 Best Places To retire in 2025

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