U.S. Supreme Court,
Tax,
Banking
Nov. 1, 2022
A Bitt[n]er pill to swallow
Supreme Court to consider method of calculating tax penalties for non-willful FBAR errors
Robert E. Dugdale
Partner
Kendall, Brill & Kelly LLP
Phone: 310-272-7904
Email: rdugdale@kbkfirm.com
Robert focuses his practrice on white collar cases and government investigations. He previously served for 19 years as an assistant U.S. attorney in the Central District of California. While working as a federal prosecutor in Los Angeles, Mr. Dugdale served as the chief assistant U.S. attorney for trials, integrity, and professionalism and, prior to that, the chief of the Criminal Division, a position in which he oversaw the work of approximately 200 federal prosecutors in the second-largest U.S. attorney's office in the nation. He can be contacted at Rdugdale@kbkfirm.com.
Albert Einstein, considered a rather bright fellow, was once quoted saying, "The hardest thing to understand in the world is the income tax." All things being relative, Mr. Einstein would be particularly confused with the IRS' stance on how it believes U.S. citizens living abroad, and others sporting U.S. citizenship who hold financial accounts overseas, should be punished for unintentional violations of the Bank Secrecy Act - a matter the Supreme Court will encounte...
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