When are Large FBAR Penalties "Excessive" Within the Meaning of the Eighth Amendment? (PDF)
Rufus Rhoades, Esq., co-author of the treatise Rhoades & Langer, U.S. International Taxation and Tax Treaties, examines when large FBAR penalties are "excessive" within the meaning of the Eighth Amendment.
Rufus v. Rhoades is the co-author of Rhoades & Langer, U.S. International Taxation and Tax Treaties, a six-volume treatise published by LexisNexis Matthew Bender. In addition to writing, Mr. Rhoades practices law with a concentration on International Tax matters and in all facets of federal and state income tax matters, including work with the Internal Revenue Service (IRS) and the California Franchise Tax Board on a number of controversial issues. Mr. Rhoades has received the Dana Latham Memorial Award for Lifetime Achievement in Taxation, which was presented by the Los Angeles County Bar Association Section on Taxation, and the Joanne Garvey Award presented by the California State Bar Section on Taxation for substantial lifetime contributions to the field of tax law.
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