Caroline D. Ciraolo was quoted in a recent Law360 article entitled “Top 5 International Tax Cases Of 2022: Midyear Report,” published on July 8, 2022. The article discusses a number of notable international tax rulings issued in the first half of 2022.
The article notes:
The Supreme Court’s resolution of the per-year-vs.-per-account dispute is critical, Kostelanetz & Fink LLP partner Caroline D. Ciraolo told Law360.
“The IRS often assesses these punitive and confiscatory penalties where little or no tax is due and the penalties far outweigh any harm inflicted,” she said. “Moreover, the IRS has taken inconsistent positions on this issue in its publications and administrative guidance. With the rapid growth of the global economy and approximately 10 million U.S. citizens living abroad, there is a critical need for an effective, fair and uniform enforcement regime with regard to FBARs.”
The case is U.S. v. Zvi Kaufman, case number 3:18-cv-00787, in the U.S. District Court for the District of Connecticut.
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