Sunday Splits
Serving You Circuit Splits Every Sunday
Arshil Sulayman | Examining the Steep Penalties for Unreported Foreign Bank Accounts Under the Eighth Amendment
The Secretary of the Treasury and the IRS require United States citizens to report any relations with foreign banks to the U.S. government through a Report of Foreign Bank and Financial Accounts Form, or FBAR. 31 U.S.C. § 5314, 31 C.F.R. § 1010.350. The maximum penalty for a willful violation of this reporting requirement is either $100,000 or 50% of the balance of each bank account at the time of the violation, whichever is the greater amount. 31 U.S.C. § 5321(a)(5)(C)(i), (D)(ii).
Benjamin Ries | Just One-Day-Late: A Split On Filing Deadlines
It’s always a terrible feeling to be late. It can incite panic as you rush to finish a task. Being late by just one day has disqualified mayoral and Presidential candidates from making it onto the ballot. In the bankruptcy context, being a day late can prevent you from escaping from sizable debts. If only you had one day more!