International Tax Attorney Minneapolis

FBAR Electronic Filing

Dec 7th, 2011 | By | Category: International Tax Attorney Minneapolis, Legal Notes

On July 18, 2011, the Financial Crimes Enforcement Network (FinCEN) announced that it has developed an electronic filing system that will accept Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts (commonly known as “FBAR”).  Once  the FBAR is filed electronically, the filers will receive an acknowledgment of each report filed. At this [...]

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Who Must File Form 8858

Nov 17th, 2011 | By | Category: International Tax Attorney Minneapolis, Legal Notes

If a U.S. person owns or is considered to be the owner of a Foreign Disregarded Entity (“FDE”), then he must file Form 8858. In general, there are three different groups of persons who may be required to file the Form. 1. Direct “Tax Owners” of FDE The instructions to Form 8858 define a “tax [...]

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Form 5471: General Overview of the Required Information

Oct 15th, 2011 | By | Category: International Tax Attorney Minneapolis, international tax lawyer st paul, Legal Notes

The individuals who fall within the four categories of U.S. persons who are required to file Form 5471 find out very fast just how incredibly complex this Form is. In addition to various problems associated with GAAP compliance, tax year adjustments, understanding very complex corporate tax and accounting rules (as well as the difference between [...]

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Foreign Tax Credit: General Overview

Sep 25th, 2011 | By | Category: International Tax Attorney Minneapolis, Legal Notes

US tax residents and citizens are taxed based upon their worldwide income. This can often result in individuals being subject to double taxation. To provide relief from this problem, the Foreign Tax Credit (FTC) provisions were enacted. There are two types of FTC’s, the direct credit and the indirect credit. Direct Foreign Tax Credit In [...]

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US-Canada Tax Treaty: Beware of Income Exemption Traps

Sep 24th, 2011 | By | Category: International Tax Attorney Minneapolis, international tax lawyer st paul, Legal Notes

Are you a US taxpayer earning income in Canada? Do you rely upon the US-Canada tax treaty (officially known as, The Convention with Respect to Taxes on Income and on Capital, U.S.-Can., Sept. 26, 1980, T.I.A.S. No. 11,087) exemptions to claim deductions or limit reporting of income for US tax purposes? If so, then you [...]

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Non-Resident Indians Face High Exposure to the FBAR Reporting Requirements

Sep 4th, 2011 | By | Category: International Tax Attorney Minneapolis, Legal Notes, voluntary disclosure lawyers Minneapolis

Non-Resident Indian (NRI) is an Indian citizen who has migrated to another country, a person of Indian origin who is born outside India, or a person of Indian origin who resides permanently outside India. A large number of the NRIs left India as a result of a job offer, for example as a software engineer [...]

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Reporting Canadian RRSPs and RRIFs in the United States: Form 8891

Jul 8th, 2011 | By | Category: International Tax Attorney Minneapolis, Legal Notes, Tax Lawyers Minneapolis

It comes as a surprise to most taxpayers the Canadian Registered Retirements Savings Plans RRSPs )and Registered Retirement Income Funds (RRIFs) must be reported in the United States.  Yet, any U.S. citizen or resident who is a beneficiary of an RRSP or RRIF must complete form 8891 and attach it to Form 1040. A U.S. [...]

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FBAR Extension for Certain Individuals: FinCEN Notices 2011-1 and 2011-2

Jul 4th, 2011 | By | Category: FBAR lawyers Los Angeles, International Tax Attorney Minneapolis, Legal Notes

On May 31, 2011, and June 17, 2011, in FinCEN Notices 2011-1 and 2011-2, the Internal Revenue Service and the Financial Crimes Enforcement Network (FinCEN) announced that a small subset of individuals, who are required to file the Report of Foreign Bank and Financial Accounts (FBAR), will receive a one-year extension beyond the recent filing [...]

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Official Treasury Currency Conversion Rates of December 31, 2010

May 15th, 2011 | By | Category: FBAR lawyers Los Angeles, International Tax Attorney Minneapolis, Legal Notes

Every quarter the U.S. Department of Treasury publishes its official currency conversion rates (they are called “Treasury’s Financial Management Service rates). While there are many uses for these rates, the current (March 2011 revision) FBAR instructions require their use, if available, to determine the maximum value of a foreign bank account. In particular, the FBAR [...]

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Tax Treaties

Mar 12th, 2011 | By | Category: International Tax Attorney Minneapolis, international tax lawyer minnesota, international tax lawyer st paul, Legal Notes

Tax treaties are bilateral agreements between two countries that generally provide relief from taxation for individuals who are covered. The U.S. has tax treaties with more than 50 different countries. The U.S. has a formulated a Model Income Tax Treaty to assist in negotiations of future tax treaties. In general, treaties will grant one country [...]

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