US Expatriate Tax Planning - Part 2 - A Podcast with Janathan Allen
Foreign Bank Account Reporting and Employment Tax Enforcement: Ronn Owens interviews Steve Moskowitz
BakerHostetler Attorneys James Mastracchio and Jay Nanavati Discuss Global Tax Enforcement
In United States v. Schwarzbaum, the Eleventh Circuit recently held that certain penalties for failure to file FBARs violated the Excessive Fines Clause of the Eighth Amendment. The district court in this case had agreed...more
Conflicting Decisions: In August, the U.S. Court of Appeals for the Eleventh Circuit held in United States v. Schwarzbaum that a monetary civil penalty imposed for willfully failing to file a foreign bank account report...more
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 clause of the Eighth...more
Last week, a federal jury in Miami found that Carl Zwerner had willfully failed to disclose his foreign bank account to the Treasury Department for calendar years 2004, 2005 and 2006. Zwerner now potentially owes the United...more