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Zhanna Ziering Talks to Tax Analysts on FBAR Penalties

August 2, 2018, Tax Analysts

In a departure from two district court opinions, the Court of Federal Claims held that the IRS's authority to impose penalties for willful failure to file foreign bank account reports is not capped at $100,000.

. . .

Similarly, Zhanna A. Ziering of Caplin & Drysdale Chtd said the heart of the cases is whether the regulation is inconsistent with the amended statute, and therefore is superseded. 

“As this issue is now pending before other district courts, we anticipate it ultimately going up to the circuit courts,” Ziering said, adding that in the meantime, the IRS “continues to have litigation hazards.

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

Excerpt taken from the article “Court Finds FBAR Penalty Can Exceed $100,000” by Kristen A. Parillo for Tax Analysts.


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