Posts Tagged ‘ international business lawyer ’

Report on Foreign Bank and Financial Accounts (FBAR): General Requirements

Nov 2nd, 2009 | By | Category: international tax lawyer minneapolis, Legal Notes, Tax Lawyers Minneapolis

Under the Bank Secrecy Act, each United States person must file a Report of Foreign Bank and Financial Accounts (the “FBAR”) with the U.S. Department of Treasury if two conditions apply.

The first condition is that the U.S. person must have either a financial interest in or signature authority (or other comparable authority)over one or more financial accounts in a foreign country. Several clarifications are necessary in order to understand the applicability of this first condition. First, for the purposes of the FBAR, the definition of a “U.S. person” includes U.S. citizens, U.S. residents, and persons in, and doing business in, the United States. “Person” is defined to include not only individuals, but also all forms of business entities, trusts, and estates.

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Significance of Income Source Rules in International Tax Law

Sep 22nd, 2009 | By | Category: international business lawyer st paul, international tax lawyer minneapolis, Legal Notes

When dealing with the international transactions, the United States tax law usually divides income into two broad categories: foreign source income and the U.S. source income. The determination of whether the income is foreign or U.S. in origin depends on a set of rules – the source-of-income rules – created by Congress, elaborated by the U.S. Treasury regulations, refined in courts, and further modified by the international treaties. While jurisdictional in nature, the income source rules are fundamentally and critically important to the understanding and operation of international transactions, primarily because these rules generate real operational consequences that affect a variety of substantive U.S. tax provisions. For the purposes of this essay, these consequences may be classified according to the grouping of the affected taxpayers.

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Understanding Foreign Income Exclusion under I.R.C. §911: General Information

Sep 5th, 2009 | By | Category: International Tax Attorney Minneapolis, international tax lawyer minneapolis, Legal Notes

Under I.R.C. §911, a U.S. citizen or resident can elect to exclude as much as $91,400 (for tax year 2009) of foreign earned income and some or all foreign housing costs from taxable gross income if two conditions are met.

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