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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 […]
A frequent question in my practice is whether a foreign account holding gold bullion is required to be reported on FinCEN Form 114 formerly Form TD F 90-22.1, usually referred to as “FBAR” (Report on Foreign Bank and Financial Accounts). FBAR is required to be filed by any U.S. person who has a financial interest […]
On June 28, 2011, Mr. Eugene Sherayzen, Esq. was elected to be the new vice-chairman of the International Business Law Section of the Minnesota State Bar Association.
The IRS generally taxes U.S. taxpayers on all income, from any source derived. Foreign taxpayers, on the other hand, will usually only pay U.S. taxes on income sourced in the U.S. However, under The Foreign Investment in Real Property Tax Act (“FIRPTA”), the IRS treats gain on the disposition of certain U.S. property and interests […]
A frequently asked tax question is whether capital gains may push a taxpayer into a higher tax bracket. This article will examine some of the tax possibilities with respect to this question. Background In general, capital gains are subject to the 0% or 15% capital gain rate. Generally, for 2010, if all of a taxpayer’s […]