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Government fails to prove taxpayer “willfully” concealed offshore bank accounts

  • Alston & Bird LLP
  • -
  • USA
  • -
  • October 15 2010

In United States v. J. Bryan Williams, a Virginia District Court found that the Government had failed to meet its burden to establish that a taxpayer willfully failed to report his interest in foreign bank accounts that were omitted from the individual’s 2000 tax return

Government fails to prove taxpayer “willfully” concealed offshore bank accounts

  • Alston & Bird LLP
  • -
  • USA
  • -
  • October 20 2010

Under foreign bank account reporting requirements, a U.S. person who has a financial interest in or signature authority over financial accounts in a foreign country where the aggregate value exceeds $10,000 is required to file a Report of Foreign Bank and Financial Accounts