Skip to Main Content

Victor Jaramillo Comments on Recent Government Win on FBAR Penalties in Bloomberg Law

December 2, 2021, Bloomberg Law

The federal government’s broad winning streak over foreign bank account reporting requirements continued this week, but an appeals court split has emerged that could soon attract the Supreme Court’s attention.

. . .

As of Tuesday, people negotiating with the IRS over FBAR penalties are in an even weaker position unless they are dealing with a non-willful penalty that is appealable to the Ninth Circuit, said Victor Jaramillo, a Member at Caplin & Drysdale.

“When the only circuit court decision out there said $10,000 per form, it gave us a way to sort of leverage the IRS to give you a sort of more reasonable settlement, but now they pretty much have every card in their hand,” Jaramillo said.

For the full article, please visit Bloomberg Law’s website (subscription required).


About Caplin & Drysdale
Celebrating our 55th Anniversary in 2019, Caplin & Drysdale continues to be a leading provider of legal services to corporations, individuals, and nonprofits throughout the United States and around the world. We are also privileged to serve as legal advisors to accounting firms, financial institutions, law firms, and other professional services organizations.

The firm's reputation over the years has earned us the trust and respect of clients, industry peers, and government agencies. Moreover, clients rely on our broad knowledge of the law and our keen insights into their business concerns and personal interests. Our lawyers' strong tactical and problem-solving skills -- combined with substantial experience handling a variety of complex, high stakes, matters in a boutique environment -- make us one the nation's most distinctive law firms.

With offices in New York City and Washington, D.C., Caplin & Drysdale's core practice areas include:
For more information, please visit us at
Washington, DC Office:
One Thomas Circle NW
Suite 1100
Washington, DC 20005
New York, NY Office:
295 Madison Avenue
12th Floor
New York, NY 10017


This communication does not provide legal advice, nor does it create an attorney-client relationship with you or any other reader. If you require legal guidance in any specific situation, you should engage a qualified lawyer for that purpose. Prior results do not guarantee a similar outcome.

Attorney Advertising
It is possible that under the laws, rules, or regulations of certain jurisdictions, this may be construed as an advertisement or solicitation.
© 2022 Caplin & Drysdale, Chartered
All Rights Reserved.

Related Professionals

Related Practice Area(s)