For some time, tax professionals have watched keenly as the case of Aroeste v. United States worked its way through a federal district court in California. In Aroeste, the taxpayer raised a novel argument that certain tax treaty provisions in the United States-Mexico tax treaty should govern whether the taxpayer had a United States FBAR reporting requirement. The government vigorously defended against this position, contending that taxpayers with dual residency should always be subject to FBAR reporting regardless of provisions in a tax treaty. On November 20, 2023, the court issued an order largely in favor of the taxpayer.
FBAR.
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