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Section on Taxation: Developments in FBAR Litigation and Enforcement
This roundtable will discuss recent developments in FBAR Litigation and Enforcement. Topics will include the current state of the willfulness standard pursuant to recent cases, the current state of multiple non-willful penalties per year, and the Bernstein Fifth Amendment FBAR litigation.
About the Speakers
Thomas Cole, Trial Attorney, Department of Justice Tax Division
Mr. Cole has been a civil trial attorney with the Department of Justice, Tax Division since 1998 and the Division’s Civil FBAR Coordinator since 2017. In addition to coordinating the Division’s FBAR civil litigation program, he has served as a trial attorney on many FBAR cases.
Zhanna A. Ziering, Member, Caplin & Drysdale
Ms. Ziering is a Member in Caplin & Drysdale’s New York office. She offers guidance to individual and corporate clients who require sophisticated tax advice concerning their domestic tax issues, offshore assets, and U.S. reporting requirements.
Ground Rules
- Statements made by government employees are made in their personal capacity and may not be relied upon as an authorized statement of any government agency.
- No recording devices allowed.
- FBA Tax Section membership is not required to participate, but you are encouraged to visit https://www.fedbar.org/membership/for information on becoming a member.
Interested in Speaking?
If you are interested in leading a future monthly call, please contact cfederico@crowell.com or brandon.king@bakermckenzie.com
If you have any questions regarding this program, please contact sections@fedbar.org