This advisory discusses a recent decision by the Seventh Circuit Court of Appeals, where the court held that the Required Records Doctrine (RRD or the “doctrine”) compelled production of subpoenaed foreign bank account records, which were required to be maintained under the Bank Secrecy Act. The district court had quashed the subpoena, concluding that it would violate the Fifth Amendment privilege against self-incrimination. The government appealed, and the court of appeals reversed the lower court’s order.
The advisory is provided in PDF on the Alston & Bird website:
www.alston.com/advisories/international-tax-advisory-september-2012
