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On December 21, 2023, the IRS and the US Department of Justice announced that Mr. Rolf Schnellmann, a Swiss national, pleaded guilty to conspiring to defraud the United States for his role in the creation and implementation of a fraud scheme related to foreign accounts and foreign income called “Singapore Solution”. In this small essay, I […]
If you reside in Duluth, Minnesota, and you have unreported foreign bank and financial accounts, you may be looking for Duluth FBAR Attorney. In your search, please consider Mr. Eugene Sherayzen of Sherayzen Law Office, Ltd. (“Sherayzen Law Office”). Let’s understand why this is the case. Duluth FBAR Attorney: International Tax Lawyer First of all, it is very important to […]
The 2023 FBAR conversion rates are very important for your US international tax compliance. The reason for their importance is their relation to FBAR (FinCEN Form 114) and the IRS Form 8938. The 2023 FBAR and 2023 Form 8938 instructions both require that 2023 FBAR conversion rates be used to report the required highest balances of foreign financial assets on these […]
If you reside in St Paul, Minnesota, and you have unreported foreign bank and financial accounts, you may be looking for St Paul FBAR Attorney. In your search, please consider Mr. Eugene Sherayzen of Sherayzen Law Office, Ltd. (“Sherayzen Law Office”). Let’s understand why this is the case. St Paul FBAR Attorney: International Tax Lawyer First of all, it is […]
Form 5471 generally requires US GAAP (Generally Accepted Accounting Practices) conversion of foreign financial statements for the purposes of reporting book income, because foreign accountants usually prepare these statements based on a different foreign standard. While Treas. Reg. Reg. §1.964-1(a)(2) contains a limited exception to the US GAAP conversion adjustments for “non-material” items (the same exception applies to […]