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Tax Analysts Quotes Zhanna Ziering: Another Court Finds FBAR Penalties Can't Exceed $100,000

July 20, 2018, Tax Analysts

Any hopes the IRS may have had of discounting as anomalous the Colliot decision, which capped willful foreign bank account reporting violation penalties at $100,000, have vanished after a second court reached the same conclusion.

. . .

Zhanna A. Ziering of Caplin & Drysdale noted that with a second district court now agreeing with the Colliot rationale, the government’s hazards of litigation have increased significantly.

“This question is now pending before multiple district courts. With taxpayer-favorable rulings in Colliot and Wahdan, there is a greater likelihood that other courts will follow,” Ziering said, adding that the issue could be appealed by the government all the way to the Supreme Court, if necessary. “In the meantime, I anticipate that we may see a flood of refund claims from taxpayers who previously paid the penalty without resorting to litigation.”


For the full article, please visit Tax Analysts' website (subscription required).

Excerpt taken from the article “Another Court Finds FBAR Penalties Can’t Exceed $100,000” by Andrew Velarde for Tax Analysts.

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