IRSMedic Debates

Justice Gorsuch’s Dissent: Are FBAR Penalties Unconstitutional?

Introduction: Unpacking Justice Gorsuch’s Dissent Justice Neil Gorsuch’s dissent in the recent case examining the constitutionality of penalties under the Foreign Bank and Financial Accounts Reporting (FBAR) statute has captured our attention. Known for his textualist approach to legal interpretation, Gorsuch raised critical questions about the limits of governmental authority in imposing severe penalties on

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IRS Form 3520 Updates: Penalty Relief for Foreign Retirement Accounts

Understanding IRS Form 3520: An Overview IRS Form 3520, formally known as the “Annual Return to Report Transactions with Foreign Trusts and Receipt of Certain Foreign Gifts,” is a critical document for U.S. taxpayers who engage in specific financial activities involving foreign entities. This form primarily serves as an informational return, ensuring compliance with U.S.

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Justice Gorsuch’s Dissent: Unpacking FBAR Penalties Debate

Introduction: The Significance of Justice Gorsuch’s Dissent In the legal sphere, dissents play an integral role by challenging majority decisions and offering alternative interpretations that may shape future judicial thought. Justice Neil Gorsuch’s dissent in the recent case concerning Foreign Bank and Financial Accounts Report (FBAR) penalties stands out as a critical lens through which

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