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Discussion about current events, culture, independent candidates, business, education, travel, death and taxes, global mobility, citizenship and residence by investment options, Americans abroad, FATCA, CRS, U.S. citizenship renunciation, Green Card abandonment, citizenship taxation, PFIC, GILTI, foreign trusts, I-407 and more ...
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Monday Jan 30, 2023
Monday Jan 30, 2023
January 30, 2023 - Participants include:
Virginia La Torre Jeker - @VLJeker
John Richardson - @Expatriationlaw
In December of 2022 the Department Of Justice sued Ms. Molynuex to recover FBAR penalties.
Significantly:
- it appears the penalties were assessed in relation to an account that she had "signing authority" over but no beneficial interest (it wasn't her account)
- the penalties assessed were more than 400% of the maximum value of the accounts
This may be a good case to accept Justice Gorsuch's invitation from the Toth case to argue that that "civil FBAR penalties" are indeed limited by the "Excessive Fines Clause" of the eighth amendment of the constitution.
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