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ARTICLE · 29 AUGUST 2022

Buff Was Kind Of Weak: FBAR Penalties

A recent FBAR case—well, kind of—serves as a reminder that FBAR penalties can be [*fill in your pejorative adjective of choice*]. In United States v. Buff, the government initiated a suit...

United StatesLitigation, Mediation & Arbitration

A recent FBAR case—well, kind of—serves as a reminder that FBAR penalties can be [*fill in your pejorative adjective of choice*]. In United States v. Buff, the government initiated a suit to collect unpaid civil penalties that it had previously assessed against Buff for violations of the Bank Secrecy Act—specifically, its requirement to file an FBAR to report foreign accounts. Buff asked the court to dismiss the government's complaint, arguing that it filed to properly serve her with process. After initially losing that battle, Buff asked the court to reconsider its ruling. It did, kind of, but decided that it was just fine with its prior ruling. Honestly, with a name like, Buff, I was hoping for more.

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