The IRS’ Authority To Seize Assets In Foreign Jurisdictions To Satisfy FBAR Penalties
By Megan L. Brackney and Luke H. Ryan The Journal of Tax Practice & Procedure Spring 2022 Abstract: In this article, Brackney and Ryan discuss the Internal Revenue Service’s (IRS’) ability to seize offshore assets to collect delinquent Report of Foreign Bank and Financial Accounts (FBAR) penalties. On May 12,