The Supreme Court's denial of certiorari to reconsider the First Circuit's United States v. Toth decision poses significant implications for U.S. residents engaged in foreign banking. [1] Swiss bank accounts are famously known for their privacy, security, and safety.[2] However, with the Supreme Court recently denying both certiorari and rehearing on a case about excessive fines on a foreign bank account, the power of the Internal Revenue Service (IRS) over such accounts has