The Constitutionality of Penalties on Undeclared Assets

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Tax Notes contributing editor Robert Goulder discusses the history of foreign bank account reporting penalties and how two recent court cases could affect the FBAR regime. 

For more coverage, read the following in Tax Notes:

• Jury Finds Professor’s FBAR Failures Willful
• FBAR Penalty Circuit Split Has Potential for Supreme Court Review
• Schwarzbaum FBAR Penalty Dispute Results in Circuit Split
• Court Tells DOJ No Do-Over in Venture Capitalist FBAR Case
• Ninth Circuit Approves Prejudgment Interest for FBAR Penalties

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• Bob Goulder: @RobertGoulder
• David Stewart: @TaxStew
• Tax Notes: @TaxNotes

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Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart