tag:blogger.com,1999:blog-1519969502186924526.post6933046635843793156..comments2023-10-24T08:00:53.865-05:00Comments on Federal Tax Crimes: Proper Base for the FBAR or "In Lieu of" FBAR penaltyJack Townsendhttp://www.blogger.com/profile/14469823736335455874noreply@blogger.comBlogger1125tag:blogger.com,1999:blog-1519969502186924526.post-86859833456212150552010-01-04T08:01:54.386-06:002010-01-04T08:01:54.386-06:00The Cittadini case is an example what you're t...The Cittadini case is an example what you're talking about above. According to the press, he had an inheritance from overseas and left it overseas, yet he was charged with the exact same violations as Rubinstein, Moran, etc and had to pay the exact same FBAR penalty, even though Moran, Rubinestein, etc. engaged in various transfers in and out of the country. <br /><br />Based on the example outlined above, the logical conclusion would seem to be that the FBAR penalty for those who left money overseas should be 25%, so that the dollar FBAR penalty would be the same as for those who transferred money back into the U.S. (ie $2,000,000 * 25% = $500,000). So, Cittadini is really paying double the penalty of the other guys and isn't facing anylesser criminal charges.Anonymousnoreply@blogger.com