The applicable penalty for the non-willful failure to file a foreign financial account is applied on a per-form basis, not a per-account basis, the U.S. Supreme Court decided Feb. 28Continue Reading Non-Willful Failure to File FBAR Under BSA Should Be Penalized on a Per-Report Basis, Supreme Court Rules for Taxpayer Against IRS
Jed Dwyer focuses his practice on white collar criminal matters, criminal and civil tax litigation, and other complex civil litigation. Jed has tried more than 40 jury and non-jury trials and has been involved in over 100 investigations and prosecutions, many of which included complex fraud and regulatory matters. Jed leverages his experience to represent individuals and organizations in investigations and other proceedings concerning tax fraud, money laundering, public corruption, complex international financial crime, financial institution fraud, and violations of the Bank Secrecy Act, among others.
Prior to joining the firm, Jed served for ten years as a federal prosecutor, first as a trial attorney with the U.S. Department of Justice, Criminal Enforcement Section, Tax Division, which Jed joined through the Attorney General’s Honors Program, and then as an Assistant United States Attorney at the U.S. Attorney’s Office for the Southern District of Florida. As a trial attorney at the Tax Division, Jed handled all aspects of complex tax fraud investigations and prosecutions in districts throughout the country. As an Assistant United States Attorney, Jed concentrated on the investigation and trial of white collar crimes, including mail and wire fraud, public corruption, money laundering and Bank Secrecy Act violations. Jed routinely worked closely with FinCEN, the OCC, and the IRS in criminal and regulatory matters involving financial institutions.