The US Tax Court has rejected a taxpayer's plea that heavy penalties for failing to file foreign trust information violated the US Constitution Eighth Amendment's excessive fines clause (Mukhi v Internal Revenue Service).

The IRS had imposed total civil fines of USD11 million on Mukhi for failing to file Forms 5471, 3520 and 3520-A to report a foreign corporation and two foreign trusts to which he transferred over USD9 million over several years......

However, the court also agreed with the judgment in Farhy v IRS that the IRS cannot automatically assess penalties under Form 5471.

News Source：【Greenberg Traurig 2024/04/15】