The Northern District of California recently determined that a taxpayer’s failure to timely file Reports of Foreign Bank and Financial Accounts (FBARs) was willful for two of four years at issue because the taxpayer affirmatively acknowledged the foreign accounts on the Schedules B for those years. The court found that the taxpayer’s failure to include Schedules B with the previous two years’ returns was not a willful violation, however.

On 1 July 2021, the Supreme Court issued its decision in the consolidated case Americans for Prosperity Foundation v. Bonta, No. 19-251 (US 1 July 2021). The Supreme Court reversed the judgment of the Ninth Circuit Court of Appeals and struck down a California donor-disclosure law as facially unconstitutional by a six to three majority.

Read publication We are pleased to enclose the March issue of Tax News and Developments, a publication of Baker McKenzie’s North America Tax Practice Group. This month’s edition features an update on the tax payment deadline, state and local tax effects of COVID-19, a discussion on the FDII regime, the…