Alston & Bird Tax Blog

International Tax ADVISORY: Taxpayer Settles for Less than 150 Percent FBAR Penalty after Jury Found Willful Failure to File

By and

This advisory discusses United States v. Zwerner, which raised important questions not only about the FBAR penalties at issue, including their constitutionality, but also about the IRS’ administration of the Offshore Voluntary Disclosure Program.

The advisory is provided in PDF on the Alston & Bird website: http://www.alston.com/advisories/june-intl-tax/

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.

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