The Tax Times: Dual Citizen Ordered to Pay $5.3M FBAR Penalty

Thursday, October 16, 2025

Dual Citizen Ordered to Pay $5.3M FBAR Penalty

According to Law360, a dual citizen Individual was ordered to pay $5.3 million in penalties and interest for willful failure to report a Swiss bank account, according to a judgment a New York federal judge issued on January 31, 2024.

U.S. District Judge granted the government's motion for default judgment against Vladimir Mrvic, which the U.S. government said it filed after Mrvic failed to respond to repeated attempts to contact him.

The Internal Revenue Service In 2019 Assessed A Penalty Of
$4.1 Million, Half The Amount In The Account In 2012, A Year For Which He Failed To Report, According To Court Documents.

As of late September, Mrvic owed $5.3 million, including $161,500 in interest and $969,000 in nonpayment penalties, the government said.

Mrvic opened an account with Swiss bank Julius Baer & Co. Ltd. in 2005 on behalf of Beaucastel Management Corp., of which he was the beneficial owner, according to court documents.

Two years after the Julius Baer account's value peaked at $11.77 million in September 2007, the Swiss bank informed Beaucastel that it needed an IRS W-9 form on file, the government said.

Rather than provide that information, the government said, Mrvic closed Beaucastel's account at Julius Baer and then transferred $5.47 million to another Swiss bank, Banque Privee Edmond de Rothschild SA. He used the funds for an "extravagant lifestyle," including purchases of condos and villas in St. Marten and Hong Kong, according to the government.

Mrvic indicated on his 2011 tax year forms that he had a foreign account, but he said he didn't need to file a form reporting it because it totaled less than $10,000, according to court documents. Mrvic deliberately misled authorities on this point, the government said.