For years, FBAR litigants have made the commonsense argument that large willful FBAR penalties, which can exceed the value of the unreported foreign accounts themselves, violate the excessive fines ...
Forbes contributors publish independent expert analyses and insights. Matthew Roberts is a tax attorney who covers tax litigation and fraud. The Bank Secrecy Act requires U.S. taxpayers to file annual ...
Forbes contributors publish independent expert analyses and insights. Admitted NY Bar and US Tax Court, covers US international tax law. FBAR obligations are confusing. They are due the same date as ...
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