New FBAR Limits Reflecting IRS Concern on Eighth Amendment Litigation. More poopourri:
or, in the words of this BNA article “New constraints on penalties the IRS will impose when taxpayers don’t properly report their foreign bank accounts show agency concerns that some will argue in court that huge penalties are unconstitutional, attorneys told Bloomberg BNA.
IRS guidance limiting the penalties examiners can assert for failure to file the Report of Foreign Bank and Financial Accounts “reflects some awareness and sensitivity about the constitutional issue presented by a multi-year FBAR penalty,” ……..
“The notion that the government will exercise some administrative restraint is a good development.”
Let the litigations begin.
(sign up for the free trial to read the whole article)