Caroline D. Ciraolo will present "The Long War Continues: Considerations In Litigating The FBAR Penalty" at the 2018 Annual Meeting of the California Tax Bar & California Tax Policy Conference

The IRS’ campaign against taxpayers with undisclosed offshore accounts and assets is entering its second decade. One of the principal weapons to enforce compliance is the civil FBAR penalty, which the IRS has been using with increasing frequency. This has resulted in a rising number of civil FBAR cases. Until recently, the primary issue has been whether the taxpayer acted willfully. However, since U.S. v. Colliot, whether the IRS can assess more than $100,000 for a willful violation has become a defense to an FBAR willful penalty. This panel will discuss strategic considerations and available defenses for taxpayers challenging an FBAR willful penalty.


  • Robert Horwitz, Attorney, Hochman, Salkin, Rettig, Toscher & Perez, P.C.
  • Caroline Ciraolo, Partner, Kostelanetz & Fink, LLP
  • Zhanna Ziering, Member, Caplin & Drysdale

Click here to register for this event. 

November 08, 2018 at 8:30am - 9:45am
Dolce Hayes Mansion
200 Edenvale Ave
San Jose, CA 95136
United States
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