Duluth FBAR Attorney | International Tax Lawyer Minnesota

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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 understand that, by looking for Duluth FBAR attorney, in reality, you are searching for an international tax lawyer who specializes in FBAR compliance.

The reason for this conclusion is the fact that FBAR enforcement belongs to a very special field of US tax law – US international tax law. FBAR is an information return concerning foreign assets, which necessarily involves US international tax compliance concerning foreign assets/foreign income. Moreover, ever since the FBAR enforcement was turned over to the IRS in 2001, the term FBAR attorney applies almost exclusively to tax attorneys.

Hence, when you look for an FBAR attorney, you are looking for an international tax attorney with a specialty in FBAR compliance.

Duluth FBAR Attorney: Broad Scope of Compliance and Offshore Voluntary Disclosures

When retaining Duluth FBAR attorney, consider the fact that such an attorney’s work is not limited only to the preparation and filing of FBARs. Rather, the attorney should be able to deliver a variety of tax services and freely operate with experience and knowledge in all relevant areas of US international tax law, including the various offshore voluntary disclosure options concerning delinquent FBARs.

Moreover, as part of an offshore voluntary disclosure, an FBAR Attorney often needs to amend US tax returns, properly prepare foreign financial statements according to US GAAP, correctly calculate PFICs, and complete an innumerable number of other tasks.

Mr. Sherayzen and his team of motivated experienced tax professionals of Sherayzen Law Office have helped hundreds of US taxpayers worldwide to bring their tax affairs into full compliance with US tax laws. This work included the preparation and filing of offshore voluntary disclosures concerning delinquent FBARs. Sherayzen Law Office offers help with all kinds of offshore voluntary disclosure options, including: SDOP (Streamlined Domestic Offshore Procedures), SFOP (Streamlined Foreign Offshore Procedures), DFSP (Delinquent FBAR Submission Procedures), DIIRSP (Delinquent International Information Return Submission Procedures), IRS VDP (IRS Voluntary Disclosure Practice) and Reasonable Cause disclosures.

Contact Sherayzen Law Office for Professional FBAR Help

Sherayzen Law Office is an international tax law firm that specializes in US international tax compliance, including FBARs. While our office is in Minneapolis, Minnesota, we help taxpayers who reside throughout the United States, including Duluth, Minnesota.

Thus, if you are looking for a Duluth FBAR Attorney, contact Mr. Sherayzen as soon as possible to schedule Your Confidential Consultation!

2023 FBAR Conversion Rates | FBAR International Tax Lawyer

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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 forms (in the case of Form 8938, the 2023 FBAR conversion rates is the default choice, not an exclusive one). In other words, the 2023 FBAR conversion rates are used to translate foreign-currency highest balances into US dollars for the purposes of FBAR and Form 8938 compliance.

The U.S. Department of Treasury  already published the 2023 FBAR conversion rates online (they are called “Treasury’s Financial Management Service rates” or the “FMS rates”).

Since the 2023 FBAR conversion rates are highly important to US taxpayers, international tax lawyers and international tax accountants, Sherayzen Law Office provides the table below listing the official 2023 FBAR conversion rates (note that the readers still need to refer to the official website for any updates).

Country – Currency Foreign Currency to $1.00
AFGHANISTAN – AFGHANI70.54
ALBANIA – LEK93.23
ALGERIA – DINAR134.051
ANGOLA – KWANZA842.5
ANTIGUA – BARBUDA – E. CARIBBEAN DOLLAR2.7000
ARGENTINA – PESO827.75
ARMENIA – DRAM400
AUSTRALIA – DOLLAR1.472
AUSTRIA – EURO0.905
AZERBAIJAN – NEW MANAT1.7
BAHAMAS – DOLLAR1.0000
BAHRAIN – DINAR0.3770
BANGLADESH – TAKA113
BARBADOS – DOLLAR2.02
BELARUS – NEW RUBLEUNAVAILABLE*
BELGIUM – EURO0.905
BELIZE – DOLLAR2
BENIN – CFA FRANC 589
BERMUDA – DOLLAR1
BOLIVIA – BOLIVIANO6.86
BOSNIA – MARKA1.769
BOTSWANA – PULA13.387
BRAZIL – REAL4.852
BRUNEI – DOLLAR1.32
BULGARIA – LEV New1.769
BURKINA FASO – CFA FRANC589
BURUNDI – FRANC2850
CAMBODIA – RIEL4051
CAMEROON – CFA FRANC593.41
CANADA – DOLLAR1.326
CAPE VERDE – ESCUDO99.75
CAYMAN ISLANDS – DOLLAR0.82
CENTRAL AFRICAN REPUBLIC – CFA FRANC593.41
CHAD – CFA FRANC593.41
CHILE – PESO880
CHINA – RENMINBI7.104
COLOMBIA – PESO3873
COMOROS – FRANC443.49
CONGO – CFA FRANC593.41
COSTA RICA – COLON519.22
COTE D’IVOIRE – CFA FRANC589
CROATIA – EURO0.905
CUBA – Chavito1
CUBA – PESO24
CYPRUS – EURO0.905
CZECH REPUBLIC – KORUNA21.731
DEM. REP. OF CONGO – FRANC2660
DENMARK – KRONE6.744
DJIBOUTI – FRANC177
DOMINICAN REPUBLIC – PESO57.9
ECUADOR – DOLARES1.0000
EGYPT – POUND30.9
EL SALVADOR – DOLARES1.0000
EQUATORIAL GUINEA – CFA FRANC593.41
ERITREA – NAKFA15
ESTONIA – EURO0.905
ESWATINI – LILANGENI18.427
ETHIOPIA – BIRR55.997
EURO ZONE – EURO0.905
FIJI – DOLLAR2.165
FINLAND – EURO0.905
FRANCE – EURO0.905
GABON – CFA FRANC593.41
GAMBIA – DALASI64
GEORGIA – LARI2.665
GERMANY – EURO0.905
GHANA – CEDI11.9
GREECE – EURO0.936
GRENADA – EAST CARIBBEAN DOLLAR2.7
GUATEMALA – QUETZAL7.815
GUINEA BISSAU – CFA FRANC589
GUINEA – FRANC8511
GUYANA – DOLLAR215
HAITI – GOURDE131.23
HONDURAS – LEMPIRA24.624
HONG KONG – DOLLAR7.811
HUNGARY – FORINT345.78
ICELAND – KRONA136.04
INDIA – RUPEE83.162
INDONESIA – RUPIAH15372.69
IRAN – RIAL42000
IRAQ – DINAR1308
IRELAND – EURO0.905
ISRAEL – SHEKEL3.619
ITALY – EURO0.905
JAMAICA – DOLLAR154
JAPAN – YEN141.47
JORDAN – DINAR0.708
KAZAKHSTAN – TENGE456.29
KENYA – SHILLING156.5
KOREA – WON1299.22
KOSOVO – EURO0.905
KUWAIT – DINAR0.307
KYRGYZSTAN – SOM89.062
LAOS – KIP20476
LATVIA – EURO0.905
LEBANON – POUND15000
LESOTHO – MALOTI18.427
LIBERIA – DOLLAR189
LIBYA – DINAR4.754
LITHUANIA – EURO0.905
LUXEMBOURG – EURO0.905
MADAGASCAR – ARIARY4564
MALAWI – KWACHA1700
MALAYSIA – RINGGIT4.59
MALDIVES – RUFIYAA15.42
MALI – CFA FRANC589
MALTA – EURO0.905
MARSHALL ISLANDS – DOLLAR1
MAURITANIA – OUGUIYA39.16
MAURITIUS – RUPEE43.87
MEXICO – PESO16.949
MICRONESIA – DOLLAR1
MOLDOVA – LEU17.25
MONGOLIA – TUGRIK3410.69
MONTENEGRO – EURO0.905
MOROCCO – DIRHAM9.855
MOZAMBIQUE – METICAL 63.25
MYANMAR – KYAT3380
NAMIBIA – DOLLAR18.427
NEPAL – RUPEE133.05
NETHERLANDS – EURO0.905
NETHERLANDS ANTILLES – GUILDER1.78
NEW ZEALAND – DOLLAR1.585
NICARAGUA – CORDOBA36.6
NIGER – CFA FRANC589
NIGERIA – NAIRA910
NORWAY – KRONE10.166
OMAN – RIAL0.385
PAKISTAN – RUPEE276.2
PALAU – DOLLAR1
PANAMA – DOLARES1
PAPUA NEW GUINEA – KINA3.727
PARAGUAY – GUARANI7249.99
PERU – SOL3.675
PHILIPPINES – PESO55.451
POLAND – ZLOTY3.924
PORTUGAL – EURO0.905
QATAR – RIYAL3.645
REP. OF N MACEDONIA – DINAR55.45
ROMANIA – NEW LEU 4.499
RUSSIA – RUBLE89.067
RWANDA – FRANC1250
SAO TOME & PRINCIPE – NEW DOBRAS22.142
SAUDI ARABIA – RIYAL3.75
SENEGAL – CFA FRANC589
SERBIA – DINAR105.92
SEYCHELLES – RUPEE13.473
SIERRA LEONE – LEONE22.7
SIERRA LEONE – OLD LEONE21.4
SINGAPORE – DOLLAR1.32
SLOVAK REPUBLIC – EURO0.905
SLOVENIA – EURO0.905
SOLOMON ISLANDS – DOLLAR8.065
SOMALI – SHILLING568
SOUTH AFRICA – RAND18.427
SOUTH SUDANESE – POUND1070
SPAIN – EURO0.905
SRI LANKA – RUPEE323.8
ST LUCIA – E CARIBBEAN DOLLAR2.7
SUDAN – SUDANESE POUND830
SURINAME – GUILDER36.723
SWEDEN – KRONA10.031
SWITZERLAND – FRANC0.838
SYRIA – POUND8585
TAIWAN – DOLLAR30.641
TAJIKISTAN – SOMONI10.93
TANZANIA – SHILLING2505
THAILAND – BAHT34.33
TIMOR – LESTE DILI1
TOGO – CFA FRANC589
TONGA – PA’ANGA2.26
TRINIDAD & TOBAGO – DOLLAR6.749
TUNISIA – DINAR3.064
TURKEY – NEW LIRA29.547
TURKMENISTAN – NEW MANAT3.491
UGANDA – SHILLING3775
UKRAINE – HRYVNIA38.089
UNITED ARAB EMIRATES – DIRHAM3.673
UNITED KINGDOM – POUND STERLING0.786
URUGUAY – PESO39.02
UZBEKISTAN – SOM12333.77
VANUATU – VATU116
VENEZUELA – BOLIVAR SOBERANO35.841
VENEZUELA – FUERTE (OLD)248832
VIETNAM – DONG24260
WESTERN SAMOA – TALA2.653
YEMEN – RIAL528
ZAMBIA – NEW KWACHA 25.71
ZIMBABWE – RTGS5801.47

*Note #1: As of the time of this article, the Department of Treasury still has not published the FBAR rate for Belarus. Please, consult the Department of the Treasury for clarification.

St Paul FBAR Attorney | International Tax Lawyer Minnesota

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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 very important to understand that, by looking for St Paul FBAR attorney, in reality, you are searching for an international tax lawyer who specializes in FBAR compliance.

The reason for this conclusion is the fact that FBAR enforcement belongs to a very special field of US tax law – US international tax law. FBAR is an information return concerning foreign assets, which necessarily involves US international tax compliance concerning foreign assets/foreign income. Moreover, ever since the FBAR enforcement was turned over to the IRS in 2001, the term FBAR attorney applies almost exclusively to tax attorneys.

Hence, when you look for an FBAR attorney, you are looking for an international tax attorney with a specialty in FBAR compliance.

St Paul FBAR Attorney: Broad Scope of Compliance and Offshore Voluntary Disclosures

When retaining St Paul FBAR attorney, consider the fact that such an attorney’s work is not limited only to the preparation and filing of FBARs. Rather, the attorney should be able to deliver a variety of tax services and freely operate with experience and knowledge in all relevant areas of US international tax law, including the various offshore voluntary disclosure options concerning delinquent FBARs.

Moreover, as part of an offshore voluntary disclosure, an FBAR Attorney often needs to amend US tax returns, properly prepare foreign financial statements according to US GAAP, correctly calculate PFICs, and complete an innumerable number of other tasks.

Mr. Sherayzen and his team of motivated experienced tax professionals of Sherayzen Law Office have helped hundreds of US taxpayers worldwide to bring their tax affairs into full compliance with US tax laws. This work included the preparation and filing of offshore voluntary disclosures concerning delinquent FBARs. Sherayzen Law Office offers help with all kinds of offshore voluntary disclosure options, including: SDOP (Streamlined Domestic Offshore Procedures), SFOP (Streamlined Foreign Offshore Procedures), DFSP (Delinquent FBAR Submission Procedures), DIIRSP (Delinquent International Information Return Submission Procedures), IRS VDP (IRS Voluntary Disclosure Practice) and Reasonable Cause disclosures.

St Paul FBAR Attorney: Out-Of-State International Tax Lawyer

Whenever you are looking for an attorney who specializes in US international tax law (which is a federal area of law, not a state one), you do not need to limit yourself to lawyers who reside in St Paul, Minnesota. On the contrary, consider international tax attorneys who reside in other states and help St Paul residents with their FBAR compliance.

Sherayzen Law Office is an international tax law firm that specializes in US international tax compliance, including FBARs. While our office is in Minneapolis, Minnesota, we help taxpayers who reside throughout the United States, including St Paul, Minnesota.

Thus, if you are looking for a St Paul FBAR Attorney, contact Mr. Sherayzen as soon as possible to schedule Your Confidential Consultation!

US GAAP Conversion of Foreign Financials: Most Common Issues | Form 5471 Lawyer

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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 tested/income loss calculation for GILTI purposes; see Treas. Reg. §1.951A-2(c)(2) (which refers to Treas. Reg. §1.952-2, which, in turn, mention the “materiality” rules of the §964 regulation)), the translation of foreign financial statements to US GAAP is a common problem for tax professionals who deal with Form 5471.

In this article, I will outline the most common issues related to the conversion of foreign financial statements to US GAAP.

US GAAP Conversion Issues: Depreciation

At the top of the US GAAP adjustments are different methods of depreciation and amortization. These differences cover pretty much all types of depreciable assets: fixed assets and intangible assets (including goodwill).

When we at Sherayzen Law Office prepare Forms 5471 for our clients, it is our standard practice to request that foreign accountants provide a detailed depreciation report, including amounts and dates concerning the purchase/sale of assets, the amortization/depreciation conventions used in foreign financial statements and the methods of accounting for increase/decrease in the value of depreciable assets.

US GAAP Conversion Issues: Inventory

Another very common area of US GAAP adjustments involves inventory. Here there could be an array of variations from FIFO/LIFO to expense capitalization methods and valuation of inventory.  Common problems arise when the inventory valuation adjustments result from related-party transactions.

For example, in one of our cases, our client had contracts of sale drafted between the head office in the United States and a foreign branch office (due to the foreign country’s requirements), making it impossible to directly rely on the foreign branch’s financial statements to determine the Cost of Goods Sold (COGS) due to varying mark-ups on tens of thousands of items.

US GAAP Conversion Issues: Valuation of Assets

One highly-problematic area for US GAAP adjustments is the valuation of assets in the foreign financial statements.  Oftentimes and in a large number of tax jurisdictions, historic cost of assets is replaced with another valuation method allowed by a local accounting standard but not by US GAAP.

We see this problem appear often in tax jurisdictions as varied as Czech Republic, Jamaica, Nigeria, Pakistan, Poland, et cetera.

US GAAP Conversion Issues: Mergers, Dissolutions and Acquisitions

Mergers, dissolutions and acquisitions may result in a bewildering array of differences between foreign financial statements and US GAAP requirements: from income recognition to asset valuation, treatment of reserve, E&P calculations and so on. Sometimes, there may be a break in the continuity of financial statements due to a dissolution of one entity and creation of another entity for US GAAP purposes while entities are treated as one entity in a foreign jurisdiction. I remember one case from Pakistan and one case from Poland where we had to make just an enormous amount of changes to bring these financial statements into compliance with US GAAP precisely due to the issues of mergers and acquisitions.

US GAAP Conversion Issues: Hyperinflation

Hyperinflation may present a US international tax attorney with its own challenges. As it is especially common in Latin America, local financials would incorporate inflationary adjustments that are incompatible with US GAAP.  An international tax lawyer has to identify these adjustments, reverse them and, if necessary, replace with adjustments required by GAAP.

US GAAP Conversion Issues: Reserves

Finally, the last most common area of problems has to do with reserves.  The problem usually arises in situations where local accounting rules permit allocation of certain reserves in a manner incompatible with US GAAP rules.

US GAAP Conversion Issues: Special Case of Consolidated Financial Statements

In a situation where a US parent company of a foreign subsidiary prepares consolidated financial statements, problems may arise with respect to whether these statements provide all relevant information needed to create a GAAP-compliant Form 5471. There are four main areas of concern in this type of cases: artificial consolidations through check-the-box rules, foreign currency fluctuations, deductions related to pensions and transfers within the group.  I will discuss these issues in more detail in a future article.

E&P Adjustments

I want to mention here that, in addition to GAAP adjustments to local financial statements, Form 5471 also requires E&P adjustments to GAAP-compliant financial statements. I will explore this topic in a future article.

Contact Sherayzen Law Office For Professional Help with Form 5471 Preparation and Offshore Voluntary Disclosures

If you are a US person who owns (fully or partially) a foreign corporation and you need to prepare a Form 5471 for a current year or any previous years, then you should contact Sherayzen Law Office for professional help.

Our international tax team, led by an international tax attorney and founder of Sherayzen Law office, Mr. Eugene Sherayzen, is a group of highly experienced and creative tax professionals with profound knowledge of US international tax law and US international tax accounting rules. We have filed hundreds of Forms 5471 in the past helping clients around the globe with their current US tax compliance as well as offshore voluntary disclosures related to prior Form 5471 noncompliance. We can help You!

Contact Us Today to Schedule Your Confidential Consultation!

Plano FBAR Attorney | International Tax Lawyer Texas

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If you reside in Plano, Texas, and you have unreported foreign bank and financial accounts, you may be looking for Plano 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.

Plano FBAR Attorney: International Tax Lawyer

First of all, it is very important to understand that, by looking for Plano FBAR attorney, in reality, you are searching for an international tax lawyer who specializes in FBAR compliance.

The reason for this conclusion is the fact that FBAR enforcement belongs to a very special field of US tax law – US international tax law. FBAR is an information return concerning foreign assets, which necessarily involves US international tax compliance concerning foreign assets/foreign income. Moreover, ever since the FBAR enforcement was turned over to the IRS in 2001, the term FBAR attorney applies almost exclusively to tax attorneys.

Hence, when you look for an FBAR attorney, you are looking for an international tax attorney with a specialty in FBAR compliance.

Plano FBAR Attorney: Out-Of-State International Tax Lawyer

Whenever you are looking for an attorney who specializes in US international tax law (which is a federal area of law, not a state one), you do not need to limit yourself to lawyers who reside in Plano, Texas. On the contrary, consider international tax attorneys who reside in other states and help Plano residents with their FBAR compliance.

Sherayzen Law Office is an international tax law firm that specializes in US international tax compliance, including FBARs. While our office is in Minneapolis, Minnesota, we help taxpayers who reside throughout the United States, including Plano, Texas.

Plano FBAR Attorney: Broad Scope of Compliance and Offshore Voluntary Disclosures

When retaining Plano FBAR attorney, consider the fact that such an attorney’s work is not limited only to the preparation and filing of FBARs. Rather, the attorney should be able to deliver a variety of tax services and freely operate with experience and knowledge in all relevant areas of US international tax law, including the various offshore voluntary disclosure options concerning delinquent FBARs.

Moreover, as part of an offshore voluntary disclosure, an FBAR Attorney often needs to amend US tax returns, properly prepare foreign financial statements according to US GAAP, correctly calculate PFICs, and complete an innumerable number of other tasks.

Mr. Sherayzen and his team of motivated experienced tax professionals of Sherayzen Law Office have helped hundreds of US taxpayers worldwide to bring their tax affairs into full compliance with US tax laws. This work included the preparation and filing of offshore voluntary disclosures concerning delinquent FBARs. Sherayzen Law Office offers help with all kinds of offshore voluntary disclosure options, including: SDOP (Streamlined Domestic Offshore Procedures), SFOP (Streamlined Foreign Offshore Procedures), DFSP (Delinquent FBAR Submission Procedures), DIIRSP (Delinquent International Information Return Submission Procedures), IRS VDP (IRS Voluntary Disclosure Practice) and Reasonable Cause disclosures.

Thus, if you are looking for a Plano FBAR Attorney, contact Mr. Sherayzen as soon as possible to schedule Your Confidential Consultation!