The Wall Street Journal has an interesting article here for tomorrow's print edition discussing the recent revelation that offshore hedge and equity fund accounts may be subject to the FBAR reporting requirements. One may wonder why this is such a revelation. Doesn't the relatively plain English cover such accounts? We have heard the term in todays economy "too big to fail." Those persons now discovering perhaps just felt earlier that they were too big to report. Stay tuned.
Addendum #1. See a Sullivan & Cromwell Memo here.
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