Skip to Main Content
 

Zhanna Ziering Comments on FBAR Litigation

June 11, 2019, Tax Analysts

A defendant is fighting for judicial review that goes beyond the administrative record in a case in which the IRS is seeking penalties for a willful failure to file a foreign bank account report.

. . .

Zhanna Ziering of Caplin & Drysdale said cases like Rum's are “finally lifting the curtain on the inner workings of the IRS” when imposing willful FBAR penalties.

“The FBAR willful penalty has become a powerful weapon for the IRS, which should be used with discretion and not as a revenue raiser. The penalties should be imposed in cases where appropriate, after the facts are fully developed and taxpayers are offered the opportunity to provide explanation or reasonable cause defenses, which should be considered before decisions are made,” Ziering said. “The IRS should be taking notice of cases like Rum’s and ensuring that the agents working the FBAR cases are properly trained and that the procedures are adhered to.”

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

Excerpt taken from the article “FBAR Litigant Fights for Review Beyond Administrative Record” by Andrew Velarde for Tax Analysts.

________________________________________________

About Caplin & Drysdale
Having celebrated our 50th Anniversary in 2014, Caplin & Drysdale continues to be a leading provider of legal services to corporations, individuals, and nonprofits throughout the United States and around the world. We are also privileged to serve as legal advisors to accounting firms, financial institutions, law firms, and other professional services organizations.

The firm's reputation over the years has earned us the trust and respect of clients, industry peers, and government agencies. Moreover, clients rely on our broad knowledge of the law and our keen insights into their business concerns and personal interests. Our lawyers' strong tactical and problem-solving skills -- combined with substantial experience handling a variety of complex, high stakes, matters in a boutique environment -- make us one the nation's most distinctive law firms.

With offices in New York City and Washington, D.C., Caplin & Drysdale's core practice areas include:
For more information, please visit us at www.caplindrysdale.com.
Washington, DC Office:
One Thomas Circle NW
Suite 1100
Washington, DC 20005
202.862.5000
New York, NY Office:
600 Lexington Avenue
21st Floor
New York, NY 10022
212.379.6000

___________________________

Disclaimer
This communication does not provide legal advice, nor does it create an attorney-client relationship with you or any other reader. If you require legal guidance in any specific situation, you should engage a qualified lawyer for that purpose. Prior results do not guarantee a similar outcome.

Attorney Advertising
It is possible that under the laws, rules, or regulations of certain jurisdictions, this may be construed as an advertisement or solicitation.
© 2019 Caplin & Drysdale, Chartered
All Rights Reserved.

Related Professionals

Related Practice Area(s)