Tax Coda

Tax Coda

United States sues New Zealand couple for $3.6 million in willful FBAR penalties

United States v. James L. Barribeau. NO. 1:25-CV-03888. District Court for the District of Columbia

Nov 12, 2025
∙ Paid

The Justice Department seeks over $3.6 million from James Barribeau and Catherine Solomon for failing to report multiple overseas bank accounts from 2005 to 2012, alleging willful FBAR violations.

Holding

The United States filed suit in the District of Columbia to collect unpaid civil penalties under 31 U.S.C. §5321(a)(5). The complaint alleges both defendants willfully failed to report their foreign bank accounts in New Zealand, Australia, South Africa, and the U.K.

Why It Matters

  • Reflects continued DOJ enforcement of long-running offshore account reporting cases.

  • Demonstrates the government’s willingness to pursue U.S. citizens living abroad for FBAR noncompliance.

  • Highlights the scale of accumulated penalties over eight years of unreported accounts.

  • Reinforces that prior FBAR filings can establish knowledge and support a willfulness finding.

Timeline

  • 1977: Barribeau and Solomon marry in New York.

  • 1984–1991: Couple resides in South Africa; later relocates to New Zealand.

  • 2003: Both obtain New …

User's avatar

Continue reading this post for free, courtesy of Tax Coda.

Or purchase a paid subscription.
© 2026 Tax Coda · Publisher Terms
Substack · Privacy ∙ Terms ∙ Collection notice
Start your SubstackGet the app
Substack is the home for great culture