
Paul L. Caron
Dean
Pepperdine Caruso
School of Law

The fuss has focused on FBARs. The FBAR requirements and penalty provisions have been hotly litigated. Recently the Supreme Court issued an opinion in Bittner v. U.S., deciding that the penalties were not as harsh as the government thought they should be. But forget FBAR. Today’s lesson is about a different, yet equally important, foreign