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Does A Treaty Govern FBAR Reporting Obligations: A Federal Court Answers “Yes” | TaxConnections Does A Treaty Govern FBAR Reporting Obligations: A Federal Court Answers “Yes”
Introduction Much of the current litigation between taxpayers and the United States has centered on the definition of willfulness or whether the non-willful FBAR penalty should apply on a per year or per account basis. Accordingly, there have been very few cases covering other requirements the United States must show to meet its burden of Does A Treaty Govern FBAR Reporting Obligations: A Federal Court Answers “Yes”