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Federal Circuit Court of Appeals Weighs In on Willful FBAR Penalties

December 16, 2019 By Edward Tanenbaum and Heather Ripley

Recently, a federal appellate court ruled in the ongoing battle between the IRS and taxpayers over the maximum penalty for willfully failing to file an FBAR to report offshore accounts as required under the Bank Secrecy Act. Our International Tax Group discusses:

  • Federal Circuit rules in favor of the IRS, upholding higher statutory ceiling
  • Lower courts have split on the issue
  • What’s next?

Read the full advisory here.

Filed Under: International Tax Advisory Tagged With: Bank Secrecy Act, BSA, Court of Appeals, FBAR, Federal Circuit, FinCen 114, IRS, Norman, Treasury

About Edward Tanenbaum

Edward Tanenbaum is co-chair of the firm’s Federal & International Tax Group and a member of the firm’s Global Resources & Strategies Committee. Mr. Tanenbaum’s practice consists primarily of planning and structuring tax efficient solutions for cross-border business transactions and investments by foreign multinational corporations and high-net-worth individuals.

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About Heather Ripley

Heather Ripley is an associate in the firm’s Federal & International Tax Group. Her practice focuses on federal and international tax services for a range of clients, including domestic and international business entities and individuals.

[Read Bio]

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