The Journal welcomes articles and essays addressing important issues in antitrust, banking, bankruptcy, corporate governance, capital markets, finance, mergers and acquisitions, securities, and tax law and practice.
I recently submitted an article I would like you to consider for publication. It is called “Bittner, FBARs, and the IRS: The Supreme Court Got This Right!”
It looks at a recent U.S. Supreme Court case where the court had to decide whether, in filing defective Foreign Bank Account Reports with the IRS, the taxpayer was liable for $50,000 in penalties for the five erroneous reports, or for $2,720,000 which was based on the 272 bank accounts he owned.
As Foreign Bank account reporting has been a hot-button topic in recent years, I am sure you agree that this is a timely article. I hope you like it and can publish it.
Harvey J. Gilmore, LL.M., J.D., MST.