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CRAWFORD v. U.S. DEPT. OF TREASURY

No. 16-3539.

868 F.3d 438 (2017)

Mark CRAWFORD; Rand Paul, in his official capacity as member of the United States Senate; Roger Johnson; Daniel Kuettel; Stephen J. Kish; Donna-Lane Nelson; L. Marc Zell, Plaintiffs-Appellants, v. UNITED STATES DEPARTMENT OF the TREASURY; United States Internal Revenue Service; United States Financial Crimes Enforcement Network, Defendants-Appellees.

United States Court of Appeals, Sixth Circuit.

Decided and Filed: August 18, 2017.

Attorney(s) appearing for the Case

ARGUED: James Bopp, Jr. , THE BOPP LAW FIRM, PC, Terre Haute, Indiana, for Appellants. Richard Caldarone , UNITED STATES DEPARTMENT OF JUSTICE, Washington, D.C., for Appellees. ON BRIEF: James Bopp, Jr. , Richard E. Coleson , Courtney Turner Milbank , THE BOPP LAW FIRM, PC, Terre Haute, Indiana, for Appellants. Richard Caldarone , Gilbert S. Rothenberg , Teresa E. McLaughlin , UNITED STATES DEPARTMENT OF JUSTICE, Washington, D.C., for Appellees.

Before: BOGGS, SILER, and MOORE, Circuit Judges.

OPINION

In 2010, Congress passed the Foreign Account Tax Compliance Act (FATCA), a law aimed at reducing tax evasion by United States taxpayers holding funds in foreign accounts. FATCA imposes account-reporting requirements (and hefty penalties for noncompliance) on both individual taxpayers and foreign financial...

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