Matthew L. Robert was quoted in a TaxNotes article “Reasons for Optimism in Seventh Amendment FBAR Challenges”

Firm partner Matthew L. Roberts was quoted in Amanda Barr’s recent TaxNotes article, “Reasons for Optimism in Seventh Amendment FBAR Challenges,” examining how recent court decisions may affect taxpayers challenging civil penalties for failing to report foreign bank accounts.

Mr. Roberts discusses how the U.S. Supreme Court’s decision in FCC V. AT&T may create opportunities for taxpayers to distinguish the FBAR penalty regime from other administrative penalty systems. He highlights key differences in the government’s ability to assess and collect FBAR penalties before a jury trial, explaining why those distinctions may offer grounds for continued Seventh Amendment challenges.