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2017 FBAR Currency Conversion Rates | FBAR Lawyer and Attorney

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Using proper currency conversion rates is a very important part of preparing 2017 FBAR and 2017 Form 8938. The instructions to both forms require (in case of FATCA Form 8938, this is the default choice) US taxpayers to use the 2017 FBAR Currency Conversion Rates published by the Treasury Department. The 2017 FBAR Currency Conversion Rates may also be used for other purposes, not just the preparation of the 2017 FBAR and Form 8938.

The 2017 FBAR Currency Conversion Rates are the December 31, 2017 rates officially published by the U.S. Department of Treasury (they are called “Treasury’s Financial Management Service rates” or the “FMS rates”) and they are the proper conversion rates that must be used while preparing FBAR and Form 8938.

Due to this importance of the 2017 FBAR Currency Conversion Rates to US taxpayers, international tax lawyers and international tax accountants, Sherayzen Law Office provides the table below the official 2017 FBAR Currency Conversion Rates (keep in mind, you still need to refer to the official website for any updates).

 

Country – Currency

Foreign Currency to $1.00
AFGHANISTAN – AFGHANI

69.3200
ALBANIA – LEK

110.6000
ALGERIA – DINAR

114.6590
ANGOLA – KWANZA

170.0000
ANTIGUA – BARBUDA – E. CARIBBEAN DOLLAR

2.7000
ARGENTINA – PESO

19.1600
ARMENIA – DRAM

485.0000
AUSTRALIA – DOLLAR

1.2790
AUSTRIA – EURO

0.8330
AZERBAIJAN – NEW MANAT

1.7100
BAHAMAS – DOLLAR

1.0000
BAHRAIN – DINAR

0.3770
BANGLADESH – TAKA

82.0000
BARBADOS – DOLLAR

2.0200
BELARUS – NEW RUBLE

1.9730
BELGIUM – EURO

0.8330
BELIZE – DOLLAR

2.0000
BENIN – CFA FRANC

562.3300
BERMUDA – DOLLAR

1.0000
BOLIVIA – BOLIVIANO

6.8600
BOSNIA – HERCEGOVINA – MARKA

1.6300
BOTSWANA – PULA

9.8040
BRAZIL – REAL

3.3120
BRUNEI – DOLLAR

1.3420
BULGARIA – LEV

1.6310
BURKINA FASO – CFA FRANC

562.3300
BURMA – KYAT

1354.0000
BURUNDI – FRANC

1720.0000
CAMBODIA (KHMER) – RIEL

4103.0000
CAMEROON – CFA FRANC

567.7900
CANADA – DOLLAR

1.2550
CAPE VERDE – ESCUDO

92.0260
CAYMAN ISLANDS – DOLLAR

0.8200
CENTRAL AFRICAN REPUBLIC – CFA FRANC

567.7900
CHAD – CFA FRANC

567.7900
CHILE – PESO

614.2300
CHINA – RENMINBI

6.5040
COLOMBIA – PESO

2981.7900
COMOROS – FRANC

411.0000
CONGO – CFA FRANC

567.7900
CONGO, DEM. REP – CONGOLESE FRANC

1580.0000
COSTA RICA – COLON

564.0000
COTE D’IVOIRE – CFA FRANC

562.3300
CROATIA – KUNA

6.2300
CUBA – PESO

1.0000
CYPRUS – EURO

0.8330
CZECH REPUBLIC – KORUNA

20.8840
DENMARK – KRONE

6.2070
DJIBOUTI – FRANC

177.0000
DOMINICAN REPUBLIC – PESO

48.1100
ECAUDOR – DOLARES

1.0000
EGYPT – POUND

17.7300
EL SALVADOR – DOLARES

1.0000
EQUATORIAL GUINEA – CFA FRANC

567.7900
ERITREA – NAKFA

15.0000
ESTONIA – EURO

0.8330
ETHIOPIA – BIRR

27.2000
EURO ZONE – EURO

0.8330
FIJI – DOLLAR

2.0170
FINLAND – EURO

0.8330
FRANCE – EURO

0.8330
GABON – CFA FRANC

567.7900
GAMBIA – DALASI

47.0000
GEORGIA – LARI

2.6100
GERMANY FRG – EURO

0.8330
GHANA – CEDI

4.5200
GREECE – EURO

0.8330
GRENADA – EAST CARIBBEAN DOLLAR

2.7000
GUATEMALA – QUENTZAL

7.3300
GUINEA – FRANC

9004.0000
GUINEA BISSAU – CFA FRANC

562.3300
GUYANA – DOLLAR

215.0000
HAITI – GOURDE

62.9500
HONDURAS – LEMPIRA

23.5000
HONG KONG – DOLLAR

7.8150
HUNGARY – FORINT

258.4500
ICELAND – KRONA

104.0900
INDIA – RUPEE

63.7500
INDONESIA – RUPIAH

13490.0000
IRAN – RIAL

36057.0000
IRAQ – DINAR

1166.0000
IRELAND – EURO

0.8330
ISRAEL – SHEKEL

3.4710
ITALY – EURO

0.8330
JAMAICA – DOLLAR

128.0000
JAPAN – YEN

112.5500
JERUSALEM – SHEKEL

3.4710
JORDAN – DINAR

0.7080
KAZAKHSTAN – TENGE

331.3100
KENYA – SHILLING

103.2000
KOREA – WON

1065.9301
KUWAIT – DINAR

0.3010
KYRGYZSTAN – SOM

69.0000
LAOS – KIP

8274.0000
LATVIA – EURO

0.8330
LEBANON – POUND

1500.0000
LESOTHO – SOUTH AFRICAN RAND

12.3160
LIBERIA – U.S. DOLLAR

125.1700
LIBYA – DINAR

1.3570
LITHUANIA – LITAS

0.8330
LUXEMBOURG – EURO

0.8330
MACAO – MOP

8.0000
MACEDONIA FYROM – DENAR

51.0700
MADAGASCAR – ARIA

3235.6201
MALAWI – KWACHA

731.0000
MALAYSIA – RINGGIT

4.0440
MALI – CFA FRANC

562.3300
MALTA – EURO

0.8330
MARSHALL ISLANDS – DOLLAR

1.0000
MARTINIQUE – EURO

0.8330
MAURITANIA – OUGUIYA

355.0000
MAURITIUS – RUPEE

33.4000
MEXICO – NEW PESO

19.7040
MICRONESIA – DOLLAR

1.0000
MOLDOVA – LEU

17.0580
MONGOLIA – TUGRIK

2427.3999
MONTENEGRO – EURO

0.8330
MOROCCO – DIRHAM

9.3520
MOZAMBIQUE – METICAL

58.8500
NAMIBIA – DOLLAR

12.3160
NEPAL – RUPEE

102.4000
NETHERLANDS – EURO

0.8330
NETHERLANDS ANTILLES – GUILDER

1.7800
NEW ZEALAND – DOLLAR

1.4050
NICARAGUA – CORDOBA

30.6000
NIGER – CFA FRANC

562.3300
NIGERIA – NAIRA

359.0000
NORWAY – KRONE

8.1960
OMAN – RIAL

0.3850
PAKISTAN – RUPEE

110.4000
PALAU – DOLLAR

1.0000
PANAMA – BALBOA

1.0000
PAPUA NEW GUINEA – KINA

3.1350
PARAGUAY – GUARANI

5574.0000
PERU – NUEVO SOL

3.2360
PHILIPPINES – PESO

49.8490
POLAND – ZLOTY

3.4830
PORTUGAL – EURO

0.8330
QATAR – RIYAL

3.6400
ROMANIA – LEU

3.8800
RUSSIA – RUBLE

57.8450
RWANDA – FRANC

855.0000
SAO TOME & PRINCIPE – DOBRAS

20597.2227
SAUDI ARABIA – RIYAL

3.7500
SENEGAL – CFA FRANC

562.3300
SERBIA – DINAR

101.3300
SEYCHELLES – RUPEE

13.3800
SIERRA LEONE – LEONE

7645.0000
SINGAPORE – DOLLAR

1.3360
SLOVAK REPUBLIC – EURO

0.8330
SLOVENIA – EURO

0.8330
SOLOMON ISLANDS – DOLLAR

7.4910
SOMALI – SHILLING

575.0000
SOUTH AFRICA – RAND

12.3160
SOUTH SUDANESE – POUND

126.0000
SPAIN – EURO

0.8330
SRI LANKA – RUPEE

153.4000
ST LUCIA – EC DOLLAR

2.7000
SUDAN – SUDANESE POUND

9.0000
SURINAME – GUILDER

7.5200
SWAZILAND – LILANGENI

12.3160
SWEDEN – KRONA

8.1930
SWITZERLAND – FRANC

0.9750
SYRIA – POUND

515.0000
TAIWAN – DOLLAR

29.6460
TAJIKISTAN – SOMONI

8.7500
TANZANIA – SHILLING

2235.0000
THAILAND – BAHT

32.6000
TIMOR – LESTE – DILI

1.0000
TOGO – CFA FRANC

562.3300
TONGA – PA’ANGA

2.1140
TRINIDAD & TOBAGO – DOLLAR

6.6300
TUNISIA – DINAR

2.4580
TURKEY – LIRA

3.7880
TURKMENISTAN – MANAT

3.4910
UGANDA – SHILLING

3635.0000
UKRAINE – HRYVNIA

28.1450
UNITED ARAB EMIRATES – DIRHAM

3.6730
UNITED KINGDOM – POUND STERLING

0.7400
URUGUAY – PESO

28.7600
UZBEKISTAN – SOM

8030.0000
VANUATU – VATU

105.0000
VENEZUELA – BOLIVAR

3345.0000
VIETNAM – DONG

22708.0000
WESTERN SAMOA – TALA

2.4400
YEMEN – RIAL

250.5000
ZAMBIA – NEW KWACHA

9.9750
ZAMBIA – KWACHA

5455.0000
ZIMBABWE – DOLLAR

1.0000

Sherayzen Law Office Ltd | US International Tax Law Firm

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Sherayzen Law Office PLLC hereby gives notice that, as of January 1, 2018, its official owner is Sherayzen Law Office, Ltd (“Sherayzen Law Office Ltd”). Sherayzen Law Office Ltd will continue to utilize “Sherayzen Law Office” as its trade name. Furthermore, Sherayzen Law Office Ltd will continue to maintain the disregarded entity (for tax purposes) Sherayzen Law Office PLLC for an indefinite period of time.

This means that Sherayzen Law Office Ltd is the official name of our international tax law firm as of January 1, 2018. Sherayzen Law Office Ltd has assumed all assets, liabilities, rights and duties of Sherayzen Law Office PLLC as of January 1, 2018.

The change in the corporate structure of Sherayzen Law Office occurred for marketing purposes. “PLLC” is a highly specified form of doing business which is not recognized outside of the United States, whereas “Ltd” is a very common form of doing business worldwide.

Sherayzen Law Office Ltd is an international tax law firm owned by attorney Eugene Sherayzen, Esq., who specializes in US international tax law. In particular, Mr. Sherayzen is a leading expert in the area of offshore voluntary disclosures (IRS Offshore Voluntary Disclosure Program (“OVDP”), Streamlined Domestic Offshore Procedures, Streamlined Foreign Offshore Procedures, Delinquent International Information Return Submission Procedures, Delinquent FBAR Submission Procedures, Reasonable Cause Disclosures, et cetera), FATCA compliance (including Form 8938, W8-BEN-E, et cetera), FBAR compliance, international tax compliance (including information returns for the ownership of a foreign business – Forms 5471, 8865, 8858, 926, et cetera), foreign trust US tax compliance (Forms 3520 and 3520-A), foreign inheritance reporting, foreign gift reporting, PFIC compliance (Form 8621), international tax planning and others.

Additionally, Sherayzen Law Office Ltd is helping its clients with domestic tax compliance, IRS audits, appeals to the IRS Office of Appeals and tax litigation.

Sherayzen Law Office Ltd operates worldwide. In fact, since 2005, Sherayzen Law Office has helped hundreds clients from close to 70 countries from every continent: Australia, North America (Canada, Mexico and the United States), South America (Argentina, Brazil, Chile and Colombia), including Central American countries like Barbados, Belize, Costa Rica, Nicaragua and Panama, Africa (Ethiopia, Ivory Coast, Nigeria), the Middle East region of Asia (Egypt, Iraq, Iran, Israel, Kuwait, Lebanon, United Emirates and so on), Southeast Asian countries (China, India, Thailand, et cetera), Far Eastern region of Asia (Japan) and the great majority of European countries (Western, Eastern, Northern and Southern Europe) including Great Britain and Ireland as well as Russia.

Contact Us Today to Schedule Your Confidential Consultation!

Broadcom Re-domiciliation Approved | International Tax Lawyer & Attorney

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On January 29, 2018, Broadcom Board of Directors approved the plan for Broadcom re-domiciliation in the United States. This move was expected after Broadcom’s November of 2017 pledge to president Trump that the company would return to the United States.

Broadcom Re-domiciliation: A Story of Tax Inversion and Tax Remorse

The story of the Broadcom re-domiciliation began fairly recently in February of 2016. At that time, Broadcom did what was very popular during the Obama administration – tax inversion. California-based Broadcom allowed itself to be acquired by Singapore’s Avago Technologies Limited with the result of creation of a single Singapore entity.

The real motivation for the inversion was lowering the corporate taxes. At that time, during the political climate that existed in the United States, Broadcom thought that it was a good move.

Now, Broadcom believes that the tax inversion might not have been such a great thing to do in light of the new developments and certain consequences that it did not seem to have anticipated prior to tax inversion. First of all, Broadcom’s business in the US has continued to expand as it stepped-up its acquisition strategy. Already in 2017, barely a year and a half after tax inversion, Broadcom has stated that the benefits of this business strategy outweigh the potential additional taxes it might have to pay when it returns to the United States (especially after the tax reform – see below).

Second and closely related to the first reason, as a foreign company based in Singapore, Broadcom is under constant scrutiny of the Committee on Foreign Investment in the United States (“CFI”). CFI focuses on the review of transactions that may result in control of a US business by a foreign person and the impact of such control on US national security. This is an irritating and expensive factor that continuously hinders Broadcom’s acquisition strategy in the United States.

Third, Broadcom apparently did not anticipate that the tax reform be so radical and so beneficial to corporations. There is one issue in particular that makes Broadcom re-domiciliation in the United States so important. At the time of its tax inversion, Broadcom established a deferred tax liability on its balance sheet with respect to integration of the company’s intellectual property (“IP”). Under the old law, this deferred tax liability would have become payable at 35% tax rate in the United States.

Now, under the Tax Cuts and Jobs Act of 2017 (“TCJA”), this deferred liability will be recognized in fiscal year 2018 as deemed repatriated foreign earnings at a much lower tax rate. This means that Broadcom re-domiciliation in 2018 will save the company a huge amount in taxes; or, as the company itself put it: “a material reduction in the amount of other long-term liabilities on our balance sheet”.

Broadcom Re-domiciliation Approved Within One Month of TCJA

The tax motivation behind Broadcom re-domiciliation became especially evident in light of the fact that the Broadcom Board approved it within just one month of the passage of TCJA. Moreover, in its filings with SEC, Broadcom directly stated that, as a result of TCJA, the tax cost of being a US-based multinational company has decreased substantially.

Sherayzen Law Office will continue to observe the impact of the recent tax reform on the behavior of US companies that went through tax inversion.

IMF Wants “Modern” Croatian Real Estate Tax | Tax Lawyer News

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On January 16, 2018, the International Monetary Fund (“IMF”) released its 2017 Article IV consultation notes with respect to Croatia. Among its recommendations is the introduction of a modern Croatian Real Estate Tax.

Croatian Real Estate Tax: IMF assessment of Croatian Economy

The IMF began on the positive note stating that, in 2017, Croatia continued its third year of positive economic growth, mostly supported by tourism, private consumption, trade partner growth and improved confidence. The IMF also noted that the fiscal consolidation was progressing at a much faster pace than originally anticipated with Croatia leaving the European Union’s Excessive Deficit Procedure in June of 2017. The international organization made other positive comments, particularly stressing that Croatia was overcoming its Agrokor crisis.

Then, the IMF turned increasingly negative. It first noted that, while the balance risks has improved, it was not satisfied with the high level of Croatian public and external debt levels. Then, it stated that the full impact of the Agrokor restructuring is not yet known. The IMF was also unhappy about the pace of structural reforms since 2013 (when Croatia became a member of the EU), further stating that Croatia’s GDP per capita stood at about 60% of the EU average and Croatian business environment remained less favorable than that of its peers.

Finally, the IMF expressed its concerns over the fact that the output did not recover from its pre-recessing level and stated that, in the medium-term, the Croatia’s economic growth is expected to decelerate. Hence, the IMF emphasized that Croatia needed to do more to improve its economic prospects.

Croatian Real Estate Tax: IMF Recommendations

What precisely does Croatia need to do in the IMF opinion? Mainly reduction of public debt.

How does the IMF recommend that Croatia accomplish this task? The IMF made a number of proposals that can be consolidated into five courses of action. First, enhance the efficiency of public services by streamlining public services. Second, keep the wages low and reform the welfare state policies (here, it probably means either slashing the state benefits or privatizing them). Third, relaxing the labor regulations, particularly in the areas of hiring and temporary employment. Fourth, enhancement of legal and property rights. Finally, improvement of the structure of revenue and expenditure.

This last enigmatic phrase is the keyword for reducing the expenses and the introduction of new taxes. In particular, the IMF wants to see an introduction of a modern Croatian real estate tax.

What is a “Modern” Croatian Real Estate Tax According to IMF

The IMF defined a “modern” Croatian real estate tax as a “real estate tax that is based on objective criteria” and the one that “would be more equitable and would yield more revenue than the existing communal fees.” The idea is that “a modern more equitable property tax could allow for a reduction of less growth-friendly taxes.” In fact, the additional revenue derived from this tax “could compensate for a further reduction in the income tax burden, the parafiscal fees, or even VAT.”

It should be noted that the Croatian government already listened to the IMF and tried to impose a Croatian real property tax starting January of 2018, but the implementation of the law was suspended in light of strong public opposition.

Sherayzen Law Office will continue to monitor the situation.

Ireland-Kazakhstan Tax Treaty Ratified | International Tax Lawyer News

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On December 29, 2017, the President of Kazakhstan Nazarbayev signed the law for the ratification of the Ireland-Kazakhstan Tax Treaty for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income.

History of the Ireland-Kazakhstan Tax Treaty

The Ireland-Kazakhstan Tax Treaty was originally signed in Astana on April 26, 2017. Ireland already ratified the treaty through Statutory Instrument 479 on November 10, 2017. By ratifying the treaty on December 29, 2017, Kazakhstan completed the process for the treaty ratification on the part of Kazakhstan.

The Ireland-Kazakhstan Tax Treaty will enter into force once the ratification instruments are exchanged. The provisions of the Treaty will apply from January 1 of the year following its entry into force. The Treaty is the first tax treaty between Ireland and Kazakhstan.

Taxes Covered by the Ireland-Kazakhstan Tax Treaty

The Ireland-Kazakhstan Tax Treaty will apply to the following taxes. With respect to Ireland, the Treaty will apply to the income tax, the universal social charge, the corporation tax and the capital gains tax. For Kazakhstan, it will apply to the corporate income tax and the individual income tax. Identical or substantially similar taxes imposed by either state after the Treaty was signed are also covered by the Treaty.

Main Provisions of the Ireland-Kazakhstan Tax Treaty

Here is an overview of the most important provisions. Obviously, this is a very general description for educational purposes only, and it cannot be relied upon as a legal advice; you should contact a licensed attorney in Ireland or Kazakhstan for legal advice.

Article 4 of the Ireland-Kazakhstan Tax Treaty defines the meaning of the term “resident”. It should be noted that the Treaty applies only to Irish and Kazakh residents (see Article 2 of the Treaty).

Article 5 defines the term Permanent Establishment.

Article 6 states that income from the “immovable” property (i.e. real estate) is subject to taxation in a country where it is located. This includes business real estate. This provision, of course, does not exempt the owner of the real estate from the obligation to also pay taxes in his home country.

Article 7 deals with business profits. It states that “the profits of an enterprise of a Contracting State shall be taxable only in that Contracting State unless that enterprise carries on business in the other Contracting State through a permanent establishment situated therein.” In the latter case, “the profits of the enterprise may be taxed in the other Contracting State but only so much of them as is attributable to that permanent establishment.”

Article 8 states that “profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that Contracting State.”

Article 9 deals with Associated Enterprises.

Article 10 establishes the maximum tax rates for dividends. In general, dividends should be taxed at a maximum rate of 5% if the beneficial owner is a company (other than a partnership) that directly holds at least 25 percent of the capital of the payer company; in all other cases, the tax rate should be no more than 15%.

Articles 11 and 12 establish the maximum tax withholding rate of 10% for interest and royalties respectively.

Articles 13 – 22, 24 and 25 deal with capital gains, employment income, director fees and certain special cases.

Article 23 establishes the usage of foreign tax credit to eliminate double-taxation under the Treaty.

Information Exchange and Tax Enforcement under the Ireland-Kazakhstan Tax Treaty

The Ireland-Kazakhstan Tax Treaty contains fairly strong provisions on the information exchange and tax enforcement. Article 26 provides for exchange of relevant tax information described in the Treaty. Article 27 obligates the signatory states to lend assistance for the purposes of collection of taxes.

Information Exchange under the Ireland-Kazakhstan Tax Treaty and FATCA Compliance

Article 26 of the Ireland-Kazakhstan Tax Treaty could be dangerous to US citizens who are also either Kazakh residents or citizens. The reason for it is FATCA which would obligate Ireland to turn over the information it receives under the Treaty directly to the IRS in cases where this information concerns noncompliant US tax residents. This may lead to an IRS investigation and the imposition of FBAR and other penalties on these US taxpayers.

Contact Sherayzen Law Office if You Have Unreported Foreign Accounts in Ireland or Kazakhstan

If you have undisclosed foreign accounts and/or foreign income in Ireland and Kazakhstan, contact Sherayzen Law Office as soon as possible. Our firm specializes in offshore voluntary disclosures and has helped hundreds of US taxpayers to deal with this issue. We can help You!

Contact Us Today for Your Confidential Consultation!