Saturday, May 19, 2018

Outstanding Presentation on Collection of Title 31 International Penalties (Including FBAR) (5/19/18)

I offer here, with permission, an updated version of Caroline Ciraolo's outstanding PowerPoint presentation (with co-panelists Sandra Brown, Jeremy Herndon, Niles Eber, and Charles Pillitteri), titled Collection of Title 31 International Penalties.  This is from a presentation at the ABA Tax Section May Meeting.  Caroline's bio is here.  I highly recommend to all who have an interest in this area.

From the "Topics" page, the subjects covered are:
  • Title 31 – Bank Secrecy Act
  • FBAR Penalties
  • Authority to Assess and Collect
  • Statute of Limitations
  • Federal Debt Collection Procedures
  • Administrative Collection Tools
  • Suits to Collect - Tax Division, U.S. Department of Justice
  • Collection of Judgments
  • Suits to Challenge FBAR Penalty
  • Bankruptcy Procedures re: FBAR Penalties

Of the foregoing, probably the most interesting for readers of this blog is Taxpayer Suits to Challenge FBAR Penalties (slides 33-35).

Thanks to Caroline.

I posted the prior version of this presentation in 2013:  FBAR Penalty Collection -- Beyond the Collection Suit, Administrative Offsets Loom Large and Long (Federal Tax Crimes Blog 4/2/13; Updated 4/10/13), here.

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