NIEMEYER, Circuit Judge.
To help combat tax evasion, the Bank Secrecy Act of 1970 requires that U.S. citizens who have foreign bank accounts report the accounts to the government on an annual basis by filing a Report of Foreign Bank and Financial Accounts, commonly referred to as an FBAR. See 31 U.S.C. § 5314(a); 31 C.F.R. § 1010...
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