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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

Manchester United ruling?

  • Alston & Bird LLP
  • -
  • USA
  • -
  • October 22 2012

LTR 201242007 is a section 351 ruling with a public offering: not a busted 351, but a good 351