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According to the IRS website:

A U.S. person, including a citizen, resident, corporation, partnership, limited liability company, trust and estate, must file an FBAR to report:

  • A financial interest in or signature or other authority over at least one financial account located outside the United States if

  • The aggregate value of those foreign financial accounts exceeded $10,000 at any time during the calendar year reported.

What is the current tax interpretation of the above statement if someone ceases to be a U.S. person (e.g. their residency ends, or they renounce their citizenship) in the middle of the year before they acquired said foreign financial interests abroad?

Would the above definition still apply? Or would it not? Since although the conditions are true, they are only satisfied after the person is no longer considered a "U.S. person"? Anyone know of any case law that addresses the period in which the definition of a "U.S. person" applies?

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