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WILSON v. UNITED STATES

Docket No. 20-603 August Term 2020.

6 F.4th 432 (2021)

Emily S. WILSON, as Executrix of the Estate of Joseph A. Wilson, the Estate of Joseph A. Wilson, Plaintiffs-Appellees, v. UNITED STATES of America, Defendant-Appellant.

United States Court of Appeals, Second Circuit.

Decided: July 28, 2021.

Attorney(s) appearing for the Case

ROBERT M. ADLER , Nossaman LLP, Washington, D.C. ( Gary Redish , Michael Cohen , Winne Banta , Basralian & Kahn, P.C., Hackensack, NJ, on the brief), for Plaintiffs-Appellees.

ELISSA HART-MAHAN , Attorney, Department of Justice, Tax Division ( Ellen Page DelSole , Attorney, Department of Justice, Tax Division, Richard E. Zuckerman , Principal Deputy Assistant Attorney General, Joshua Wu , Deputy Assistant Attorney General, Richard P. Donoghue , United States Attorney, on the brief), for Merrick B. Garland , United States Attorney General, Washington, D.C., for Defendant-Appellant.

Before: LIVINGSTON, Chief Judge, WESLEY, CARNEY, Circuit Judges.

Joseph Wilson was the sole owner and beneficiary of an overseas trust. Section 6048 of the Internal Revenue Code ("IRC") requires U.S. owners of a foreign trust to ensure that the trust files an annual return, see 26 U.S.C. § 6048(b), and U.S. beneficiaries of a foreign trust to file a return reporting the distributions...

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