Tax,
Government,
Banking
Oct. 26, 2022
Bittner - another illegal money grab
Creating a distinction in Section 5314 between the reporting form and the reporting itself is nothing more than a creative distinction without a difference to achieve a goal: more money from the taxpayer.
As SCOTUS noted in Cal. Bankers Ass'n v. Shultz, 416 U.S. 21, 27 (1974), the primary purpose of the Bank Secrecy Act (BSA) is to curb the "serious and widespread" use of foreign financial accounts to evade taxes. On its website, the Financial Crimes Enforcement Network (FinCEN) states, "[a] United States person that has a financial interest in or signature authority over foreign financial accounts must file an FBAR [FINCEN form 114] if the aggregate val...
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