Victor Jaramillo Comments on Recent Government Win on FBAR Penalties in Bloomberg Law

Bloomberg Law

The federal government’s broad winning streak over foreign bank account reporting requirements continued this week, but an appeals court split has emerged that could soon attract the Supreme Court’s attention.

. . .

As of Tuesday, people negotiating with the IRS over FBAR penalties are in an even weaker position unless they are dealing with a non-willful penalty that is appealable to the Ninth Circuit, said Victor Jaramillo, a Member at Caplin & Drysdale.

“When the only circuit court decision out there said $10,000 per form, it gave us a way to sort of leverage the IRS to give you a sort of more reasonable settlement, but now they pretty much have every card in their hand,” Jaramillo said.

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