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Zhanna Ziering Comments on Colliot and Wahdan Cases

June 26, 2018, Tax Analysts

The U.S. government is not willing to let a sea change overtake its foreign bank account reporting penalty regime without another fight, following a notable loss in a district court case.

. . .

"The government carefully went through the Colliot decision in an attempt to rebut each of the courts conclusions," Zhanna A. Ziering of Caplin & Drysdale said. "Given the potential monumental impact of both the Colliot and Wahdan cases, we are watching both of these cases closely as there may be a potential circuit split on this issue."

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

Excerpt taken from the article “U.S. Government Seeks to Nip Colliot FBAR Decision in the Bud” by Andrew Velarde for Tax Analysts.


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