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Try CasePortal for FreeJ. Seabright denies summary judgment to the government and the IRS in case of a Japanese resident’s failure to file a foreign bank account report for several years. The failure to file was likely not willful, but rather a result of the fact that the resident does not speak English and lives primarily in Japan, and relied on an accountant and a mistranslated form that indicated that non-residents were exempt from this filing.
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