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Ida Varshavsky

Ida Varshavsky is an associate in Baker McKenzie's Tax and Global Wealth Management practice groups in Zurich.

In Mendu v. United States, the Court of Federal Claims held that penalties for failure to timely file a Report of Foreign Bank and Financial Accounts (FBAR), commonly known as “FBAR penalties,” were not subject to the Flora full payment rule, which requires a plaintiff to make payment of the full tax amount before they bring suit in the Court of Federal Claims or any US district court for the refund of any “internal-revenue tax.”

On 28 September 2020, the Treasury Inspector General for Tax Administration published the Final Audit Report (“Report”). The Report was originally initiated to determine the effectiveness of the IRS efforts in ensuring compliance with the expatriation tax provisions under sections 887 and 877A, and related efforts to reduce taxpayer’s burden.

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