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Archive for September 2009

2009 Sept # – Sardar

Michael Sardar
The FBAR and the Fifth Amendment
Journal of Taxation 111:3 (Sept 2009) 180-182


10 footnotes. Sardar concludes: “It appears that in certain circumstances a taxpayer can make a persuasive argument — distinguishing the Sixth Circuit’s decision in Sturman on the grounds discussed above — that the filing of an FBAR would amount to self-incrimination in violation of the Fifth Amendment, and that the failure to file an FBAR is therefore justified.”

Written by usxcanada

1 September 2009 at 6:00 am