Entries by Manager

Minnesota Money Transmitter License Application: Required Enclosures

When a business entity applies for a Minnesota money transmitter license, the applicant must be aware that, in addition to answering the questions on the application, the Department of Commerce (“Department”) requires a large number of additional documents that must accompany the original license application. While the precise nature of the required documentation varies depending […]

Minnesota Money Transmitter License Application: Expiration of Initial License Considerations

Applying for a money transmitter license in Minnesota can be an expensive enterprise, and the applicant should make sure that he will be able to maximize the benefits that can be derived from the license. The definition of the licensed period, therefore, becomes one of the most important considerations. The Department of Commerce (“Department”) states […]

FBAR: Financial Interest, Signature Authority, and Other Comparable Authority

One of the major requirements that gives rise to the obligation to file the FBAR is that a U.S. person has either a financial interest in, or a signature authority or other comparable authority over the relevant foreign financial accounts. In deciding whether the FBAR is required, it is useful to go through all three […]

FBAR Penalties

In this essay, I would like to discuss some of the penalties that may be imposed as a result of the failure to file the FBAR even though you were required to do so. In particular, I will focus on three general scenarios describing specific penalties commonly attributed to each of them. The first scenario […]

FBAR: Aggregate Value Requirement

FBAR filing is required only if the aggregate balances of a U.S. person‘s foreign financial accounts exceed $10,000. Despite appearances, the requirement that the aggregate value of all of the foreign financial accounts exceeds $10,000 at any time during a calendar year is not without complications. In order to figure out the account value in […]