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- Title
FBAR Penalties and U.S. v. Zwerner.
- Authors
Press, Martin R.; Hill, Nathan W.
- Abstract
The article discusses the penalties imposed by the U.S. Internal Revenue Service (IRS) for violation of the Report of Foreign Bank and Financial Accounts (FBAR) in the court case United States v. Zwerner. Topics include a brief history of the Bank Secrecy Act, the government's burden of proof in FBAR lawsuits, and the disputed issue of willfulness in such cases. Also mentioned is an overview of the Zwerner case and the application of the Eight Amendment to it.
- Subjects
UNITED States; UNITED States. Internal Revenue Service; FOREIGN bank account laws; BUSINESS reporting to government; ACTIONS &; defenses (Law); LEGISLATION; CONFIDENTIAL communications in banking; BURDEN of proof; UNITED States. Constitution. 8th Amendment; LAW
- Publication
International Tax Journal, 2015, Vol 41, Issue 1, p17
- ISSN
0097-7314
- Publication type
Article