FBAR Lawyers

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

2017 FBAR Deadline | FinCEN Form 114 FBAR Lawyer & Attorney

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FinCEN recently confirmed the 2017 FBAR deadline and the automatic extension option.

2017 FBAR Deadline: FBAR Background

FinCEN Form 114, the Report of Foreign Bank and Financial Accounts, is commonly known as FBAR.  US taxpayers should use this form to report their financial interest in or signatory authority over foreign financial accounts. Failure to timely file the FBAR may result in the imposition of draconian FBAR penalties.

2017 FBAR Deadline: Traditional FBAR Deadline

Prior to 2016 FBAR, the taxpayers had to file their FBARs for each relevant calendar year by June 30 of the following year. No filings extensions were allowed. The last FBAR that followed this deadline was 2015 FBAR (its due date was June 30, 2016).

2017 FBAR Deadline: Changes to FBAR Deadline Starting 2016 FBAR

The Surface Transportation and Veterans Health Care Choice Improvement Act of 2015 (the “Act”) changed the FBAR deadline starting with 2016 FBAR.  Section 2006(b)(11) of the Act requires the FBARs to be filed by the due date of that year’s tax return (i.e. usually April 15), not June 30.

Furthermore, during the transition period, the IRS granted to US taxpayers an automatic extension of the FBAR filing deadline to October 15. The taxpayers do not need to make any specific requests in order for extension to be granted.

In other words, starting 2016 FBAR, the Act adjusted the FBAR due date to coincide with the federal income tax filing deadlines. Moreover, the new FBAR filing deadline will follow to the letter the federal income tax due date guidance. The federal income tax due date guidance states that, in situations where the tax return due date falls on a Saturday, Sunday, or legal holiday, the IRS must delay the due date until the next business day.

2017 FBAR Deadline

Based on the new law, the 2017 FBAR deadline will be April 17, 2018 (same as 2017 income tax return due date). If a taxpayer does not file his 2017 FBAR by April 17, 2018, then the IRS will automatically grant an extension until October 15, 2018. Failure to file 2017 FBAR by October 15, 2018, may result in the imposition of FBAR civil and criminal penalties.

FBAR Safe Deposit Box Reporting | FBAR Tax Lawyer & Attorney

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One of the most common questions that US taxpayers have is regarding FBAR Safe Deposit Box reporting requirements. While the general answer is clear, there may be complications in certain cases.

General FBAR Safe Deposit Box Reporting Requirements

In general, a safe deposit box is not considered to be a financial account and, therefore, not reportable on FBAR.

This is a general rule and it is important to understand that it applies only to a safe deposit box – i.e. an individually secured container, usually held within a larger safe or bank vault. It is important to understand that the bank vault itself is NOT a safe deposit box. In fact, if you were to store gold in a bank vault with bank employees able to directly and legally access the contents of your storage, you would create a reportable account.

The most common example of accounts created by storing items in a bank vault are precious metals, particularly gold and silver (but also any other similar accounts, such as rare minerals accounts).

Exception: FBAR Safe Deposit Box Reporting May Arise If Custodial Relationship Is Established With Respect to the Safe Deposit Box

The great majority of cases are easily resolved under the general rule. However, as I hinted at above, an FBAR safe deposit box reporting requirement may arise if the owner of a safe deposit box enters into a custodial relationship with respect to this safe deposit box.

In such situations, a foreign financial institution is usually given direct legal access to the safe deposit box, is responsible for the safety of its contents and may change the contents according to the instructions from the box’s owner. Of course, in such a case, a safe deposit box can hardly be called in such a way and becomes very similar to a regular bank vault account.

This exception is very rare. I have personally encountered such exceptions only in the context of precious metals accounts.

Contact Sherayzen Law Office for Professional Help With Your FBAR Reporting Requirements

If you need professional help with your FBAR filings, or if you have not timely filed your FBARs for past years and need to resolve your past tax noncompliance, please contact Sherayzen Law Office. Our experienced legal team of tax professionals, headed by our international tax attorney Eugene Sherayzen, will thoroughly analyze your case, determine the US tax reporting requirements that may apply to your case, develop your voluntary disclosure plan and implement it.

Contact Us Today to Schedule Your Confidential Consultation!

A Senior Citizen With Offshore Accounts in Panama Pleads Guilty | IRS News

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On May 26, 2017, the IRS scored another victory against Offshore Accounts in Panama and again against a senior citizen. This time, Ms. Joyce Meads, a 73-year old Texas resident, pleaded guilty to conspiring to defraud the United States by using offshore accounts in Panama to conceal more than $1.3 million in royalty income that she earned from oil wells.

Offshore Accounts in Panama: Facts of the Meads Case

According to documents and information provided to the court, from approximately April of 1997 through April of 2010, Ms. Meads conspired with offshore promoters to disguise more than $1.3 million in royalty income (from oil wells) as scholarships and loans from a foreign corporation that she set up.

In particular, Ms. Meads set up nominee companies in Delaware and Panama in the name of W.G. Holdings Corporation. Then, she transferred her interest in the oil wells to the nominee entity in Delaware, which resulted in all of the royalty checks to be issued to W.G. Holdings and sent to a Miami post office box. The checks were picked up there and sent by a courier to Panama to be deposited into Ms. Meads’ nominee accounts. Later, as it was mentioned above, the funds were repatriated as scholarships or loans from W.G. Holdings to herself. Ultimately, the funds ended up on her bank accounts and the accounts that were opened in her mother’s name.

During all of the relevant years, Ms. Meads never reported her income on her tax returns. Nor did she ever file an FBAR with respect to her offshore account in Panama. As part of the guilty plea, Ms. Meads admitted that she caused a tax laws of more than $250,000.

The IRS identified the promoters who helped Ms. Meads in her conspiracy to evade taxes. They are Marc Harris of The Harris Organization, Republic of Panama, and Boyce Griffin of Offshore Management Alliance Ltd., Republic of Panama. Both of them have already been convicted of conspiracy and other charges and were previously sentenced to prison.

Offshore Accounts in Panama: Potential Jail Time and FBAR Penalties

The sentencing of Ms. Meads is scheduled for August 4, 2017. Ms. Meads faces a statutory maximum sentence of five years in prison, a period of supervised release, restitution and monetary penalties. The penalties will likely include not only income tax fraud penalties, but also FBAR penalties.

Offshore Accounts in Panama: Lessons from the Meads Case

The Meads case is a classic example of a situation that leads to an IRS criminal investigation. Let’s focus on three main factors here.

First, Ms. Meads was diverting pre-tax US-source income from the United States to an offshore tax shelter. Based just on this fact, the IRS has sufficient incentive to make an example of her. In fact, diverting US-source income to a tax shelter might be the most important factor that led to criminal penalties in this case.

Second, Ms. Meads utilized a shell corporations to hide her income. Involving foreign companies in a tax evasion scheme is a very common factor that leads to an IRS criminal investigation.

Finally, Ms. Meads utilized secret offshore accounts in Panama in her tax evasion scheme – accounts that she never disclosed on her FBARs. By doing so, she granted to the IRS a very powerful weapon in the form of draconian FBAR penalties, not just criminal but also civil. This means that the IRS had a trump card in court to force Ms. Meads to agree to a guilty plea. In other words, with FBAR penalties as a major negotiation weapon, the IRS feels confident to press with the criminal charges for the entire case. While in the Meads case proving the rest of the charges might not have been very difficult, this is not the situation in a lot of other cases.

Contact Sherayzen Law Office for Professional Help With Disclosing Your Offshore Accounts in Panama and Any Other Foreign Country

If you have undisclosed foreign accounts or any other foreign assets, contact Sherayzen Law Office as soon as possible. Time may be of the essence, because an IRS investigation may prevent you from participating in any of the main Offshore Voluntary Disclosure initiatives (now closed).

With Sherayzen Law Office, you can feel confident that expertise, experience and convenience is on your side! We have helped hundreds of US taxpayers around the world to bring their tax affairs into full compliance with US tax laws, and We Can Help You!

Contact Us Today to Schedule Your Confidential Consultation!

Indianapolis FBAR Lawyer | Foreign Accounts Tax Attorney

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One of the advantages of practicing US international tax law is that an international tax lawyer can offer his FBAR services throughout the United States. Why is this case? Why is an international tax lawyer who lives in Minneapolis considered as an Indianapolis FBAR Lawyer?

Indianapolis FBAR Lawyer: FBAR is Federal Law, Not State Law

The answer to the question above is not difficult and, in fact, very logical. FBAR is a part of US federal law and no local law plays a role in defining its requirements or its implementation. This means that any US international tax lawyer can offer FBAR services in any of the 50 states and the District of Columbia irrespective of his physical location. This further means that a lawyer in Minneapolis can be considered as an Indianapolis FBAR Lawyer even though he never visited the State of Indiana.

Indianapolis FBAR Lawyer Must Be a US International Tax Lawyer

It is worth emphasizing that an Indianapolis FBAR Lawyer must be a US international tax lawyer, not just any lawyer. This emphasis is very important because FBAR forms are part of the US international tax law and its penalty structure is deeply connected with a taxpayer’s overall tax compliance. In a voluntary disclosure situation, the relationship between FBAR and the overall US international tax compliance may play a determinative role in the legal position of a taxpayer.

A sophisticated reader might wonder why FBAR forms are part of the US international tax law if the FBAR was created as a result of the Bank Secrecy Act (i.e. Title 31 of the United States Code), whereas the entire Internal Revenue Code is located in Title 26 of the United States Code. The answer is not that simple and deserves a special article.

Nevertheless, I can provide a short answer here: FBAR is administered by the IRS and, as part of its historic evolution, the form became a tax enforcement mechanism.

Sherayzen Law Office Can Be Your Indianapolis FBAR Lawyer

If you are looking for an Indianapolis FBAR Lawyer, Sherayzen Law Office may be the perfect fit for you! Sherayzen Law Office is an international tax law firm that specializes in US tax compliance, including FBARs. We have profound knowledge of this area of law and the extensive experience in helping clients with international tax law issues, including offshore voluntary disclosures with respect to delinquent FBARs. We have helped hundreds of US taxpayers worldwide with their FBAR issues and we can help You!

Contact Sherayzen Law Office today to schedule Your Confidential Consultation!