; and any amount or thing of value paid or transferred by or on behalf of a United States person directly or indirectly to an account, or entity that holds an account, or in any other manner has assets, in a non-FATCA institution, represents previously unreported income of such person taxable in the year of the transfer. (c) Rebutting the presumptions The presumptions established in this section may be rebutted only by clear and convincing evidence, including detailed documentary, testimonial, and transactional evidence, establishing that— (1) in subsection (a), such taxpayer exercised no control, directly or indirectly, over account or entity at the time in question, and (2) in subsection (b), such amounts or things of value did not represent income related to such United States person. Any court having jurisdiction of a civil proceeding in which control of such an offshore account or offshore entity or the income character of such receipts or amounts transferred is an issue shall prohibit the introduction by the taxpayer of any foreign based document that is not authenticated in open court by a person with knowledge of such document, or any other evidence supplied by a person outside the jurisdiction of a United States court, unless such person appears before the court. . (B) The table of subchapters for chapter 76 is amended by inserting after the item relating to subchapter E the following new item: Subchapter F. Presumptions for certain legal proceedings . (2) Definition of non-fatca institution Section 7701(a) is amended by adding at the end the following new paragraph: (51) Non-fatca institution The term non-FATCA institution means any foreign financial institution that does not meet the reporting requirements of section 1471(b). . (3) Presumptions for securities law purposes Section 21 of the Securities Exchange Act of 1934 ( 15 U.S.C. 78u ) is amended by adding at the end the following new subsection: (j) Presumptions pertaining to control and beneficial ownership (1) Control For purposes of any civil