Aroeste v. United States – Sets Precedent Relating to the Tiebreaker Clause in United States-Mexico Tax Treaty.
In Aroeste v. United States, the U.S. District Court of the Southern District of California held Mr. Aroeste is not liable for the penalties for alleged violation of the Report of Foreign Bank and Financial Accounts (FBAR) because he was a US Nonresident as determined by Article 4 of the United States-Mexico Tax Income Treaty (the Treaty) and therefore, was not required to file FBAR.