Key legal question
Whether the appellate court acted arbitrarily and violated in dubio pro reo by rejecting the alleged foreign trustee explanation for the funds.
Extracted holding
The evidentiary assessment was not arbitrary; the alleged trustee story was unsupported and implausible.
Extracted reasoning
The absence of documents, the unclear accounts, and the implausibility of using a foundation for covert tax evasion supported the finding that the funds belonged to the foundation.