A&O Shearman was formed in 2024 via the merger of two historic firms, Allen & Overy and Shearman & Sterling. With nearly 4,000 lawyers globally, we are equally fluent in English law, U.S. law and the laws of the world’s most dynamic markets.
This combination creates a new kind of law firm, one built to achieve unparalleled outcomes for our clients on their most complex, multijurisdictional matters – everywhere in the world. A firm that advises at the forefront of the forces changing the current of global business and that is unrivalled in its global strength.
Our clients benefit from the collective experience of teams who work with many of the world’s most influential companies and institutions, and have a history of precedent-setting innovations.
Together our lawyers advise more than a third of NYSE-listed businesses, a fifth of the NASDAQ and a notable proportion of the London Stock Exchange, the Euronext, Euronext Paris and the Tokyo and Hong Kong Stock Exchanges.
On October 28, the IRS revised Internal Revenue Manual 8.11.6
regarding penalties applicable for failure to file a Report of
Foreign Bank and Financial Accounts ("FBAR").1
The new provisions address electronic FBAR filing, which became
mandatory on July 1, 2013, and explain when Fast Track Settlement
and Fast Track Mediation are available. Under the new provisions,
pre-assessed FBAR penalties are eligible for Fast Track Settlement
only if the FBAR 30-day letter, Letter 3709, has not been issued to
the taxpayer. The revised manual also provides that pre-assessed
FBAR penalties are eligible for Fast Track Mediation. The new
provisions clarify when Alternative Dispute Resolution
("ADR") rights are not available for FBAR cases:
post-assessed FBAR penalties do not have ADR rights. In addition to
referencing interest accrual on, and joint and several liability
for, FBAR penalties, the new provisions change the time for
completing post assessed FBAR cases from 60 days to 120 days.
Footnote
1 I.R.M. 8.11.6.
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.
