2023 IRS Quarterly Interest Rates on Overpayment/Underpayment of Tax

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The 2023 IRS quarterly interest rates IRS interest rates are relevant for a great variety of purposes. Let’s highlight three of its most important uses. First, these rates will determine the interest a taxpayer will get on any IRS refunds.

Second, the 2023 IRS quarterly interest rates will also be used to establish the interest to be added to any additional US tax liability on amended or audited tax returns. This also applies to the tax returns that were amended under the Streamlined Domestic Offshore Procedures and Streamlined Foreign Offshore Procedures.

Finally, the 2023 IRS quarterly interest rates will be used to calculate PFIC interest on any relevant §1291 PFIC tax. This PFIC interest will be reported on the relevant Form 8621 and ultimately Form 1040.

We at Sherayzen Law Office constantly deal with the IRS interest rates on overpayments and underpayments of tax. This is why we closely follow any changes in these IRS interest rates, including the 2023 IRS quarterly interest rates.

Below, I lay our the 2023 IRS quarterly interest rates for each quarter.

How the 2023 IRS quarterly Interest Rates Are Calculated

Internal Revenue Code (“IRC”) §6621 establishes the IRS interest rates on overpayments and underpayments of tax. Under §6621(a)(1), the overpayment rate is the sum of the federal short-term rate plus 3 percentage points for individuals and 2 percentage points in cases of a corporation. There is an exception to this rule: with respect to a corporate overpayment of tax exceeding $10,000 for a taxable period of time, the rate is the sum of the federal short-term rate plus one-half of a percentage point.

Under §6621(a)(2), the underpayment rate is the sum of the federal short-term rate plus 3 percentage points. Again, there is an exception for a large corporate underpayment: in such cases, §6621(c) requires the underpayment rate to be the sum of the relevant federal short-term rate plus 5 percentage points. The readers should see §6621(c) and §301.6621-3 of the Regulations on Procedure and Administration for the definition of a large corporate underpayment and for the rules for determining the applicable date.

2023 First Quarter IRS Interest Rates

On November 29, 2022, the IRS announced another increase in the IRS interest rates on overpayment and underpayment of tax.

This means that, effective on January 1, 2023 the First Quarter 2023 IRS interest rates are as follows:

seven (7) percent for overpayments (six (6) percent in the case of a corporation);

seven (7) percent for underpayments;

nine (9) percent for large corporate underpayments; and

four and a half (4.5) of a percent for the portion of a corporate underpayment exceeding $10,000.

2023 Second Quarter IRS Interest Rates

On February 13, 2023, the Internal Revenue Service announced that interest rates would remain the same for the calendar quarter beginning April 1, 2023.  In other words, the first quarter and the second quarter IRS interest rates were exactly the same.

2023 Third Quarter IRS Interest Rates

On May 22, 2023, the Internal Revenue Service announced that interest rates would remain the same for the calendar quarter beginning July 1, 2023.  In other words, the IRS interest rates remained the same for the first three quarters of 2023.

2023 Fourth Quarter IRS Interest Rates

On August 25, 2023, the Internal Revenue Service announced that it would increase the interest rates for the calendar quarter beginning October 1, 2023.

  • This means that, the Fourth Quarter 2023 IRS interest rates are as follows:
  • eight (8) percent for overpayments (seven (7) percent in the case of a corporation);
  • eight (8) percent for underpayments;
  • ten (10) percent for large corporate underpayments; and
  • five and a half (5.5) of a percent for the portion of a corporate underpayment exceeding $10,000.

Child FBAR Obligations | FBAR Tax Lawyer & Attorney

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Child FBAR filing obligations is a topic that comes up fairly often in my practice. In this short essay, I will discuss whether a child is required to file an FBAR and how it should be done.

Child FBAR Obligations: What is FBAR

FBAR is a common abbreviation for the Report of Foreign Bank and Financial Accounts, officially called FinCEN Form 114, Report of Foreign Bank and Financial Accounts (used to be TD F 90-22.1). This form is used by US persons to report to the IRS a financial interest in or signatory authority over foreign financial accounts.  This is one of the most important forms that US taxpayers need to file in order to comply with their US international tax law requirements. A failure to file an FBAR when required may result in an imposition of severe IRS penalties.

Child FBAR Obligations: No Age Limitations

All US Persons are potentially subject to the FBAR requirement with no regard for their age. In other words, minor children with foreign accounts that satisfy the FBAR filing threshold must file FBARs. Even a newborn infant may have to file an FBAR. See BSA Electronic Filing Requirements For Report of Foreign Bank and Financial Accounts (FinCEN Form 114), p. 6.

Child FBAR Obligations: How to file a Child’s FBAR

While a child is responsible for the filing of his own FBAR, the child’s parent, guardian or other legally responsible person must file the FBAR for the child if the child is unable to do it himself.  Id. In such cases, the responsible person, parent or guardian must sign the FBAR on behalf of the child as “Parent/Guardian filing for child”.

Contact Sherayzen Law Office for Professional Help with Your Child FBAR Obligations

Parents often overlook their children’s FBAR obligations.  Time and again, I discover that otherwise fully-compliant taxpayers completely neglected their children’s FBARs.

If your child has not filed the required FBARs or he needs help complying with his current FBAR obligations, contact Sherayzen Law Office for professional help.  We are a highly-experienced team of international tax professionals led by an international tax attorney, Mr. Eugene Sherayzen.  We have helped hundreds of people around the world with their FBAR obligations, including offshore voluntary disclosures, and we can help you!

Contact Us Today to Schedule Your Confidential Consultation!

Tax Treaty Election FBAR Obligations | FBAR Lawyer & Attorney

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In my practice, I often receive calls from people who are confused about their FBAR obligations.  A recent call raised an important issue of whether a tax treaty election may affect one’s FBAR obligations.  In this brief article, I would like to address this issue of tax treaty election FBAR obligations.

Tax Treaty Election FBAR Obligations: What is FBAR ?

FinCEN Form 114, Report of Foreign Bank and Financial Accounts (used to be TD F 90-22.1) is commonly known as FBAR, the Report of Foreign Bank and Financial Accounts. This form is used by US persons to report to the IRS a financial interest in or signatory authority over foreign financial accounts.  This is one of the most important forms that US taxpayers need to file in order to comply with their US international tax law requirements. A failure to file an FBAR when required may result in an imposition of severe IRS penalties.

Tax Treaty Election FBAR Obligations: US Person

In another article, I already addressed in great detail the definition of a US Person.  Here, I will just briefly state the categories of persons who fall under the definition of a US Person for FBAR purposes:

(1) US citizens;

(2) residents of the United States;

(3) an entity, such as a corporation, partnership and a limited liability company, created or organized in the United States or under the laws of the United States;

(4) a trust formed under the laws of the United States; and

(5) an estate formed under the laws of the United States.

Tax Treaty Election FBAR Obligations: US Person & Tax Treaty Election

Now, we have come to the critical point and the main subject of this essay: would a tax treaty election to be treated as a resident of another country under a valid income tax treaty affect one’s FBAR obligations? In other words, can you elect out of being a US Person by making a tax treaty election?

The main general answer is no – a tax treaty does not and cannot affect FBAR filing obligations. See Amendment to the Bank Secrecy Act Regulations—Reports of Foreign Financial Accounts, 76 Fed. Reg. 10, 234 & 238 (Feb. 24, 2011); also, IRM 4.26.16.2.1.2(6) (11-06-15).  If a person meets the definition of a resident alien under IRC §7701(b) (i.e. he meets the FBAR definition of a US Person), even if he is not treated as a resident for income tax purposes due to an election under an income tax treaty, he will still be subject to FBAR.

The main exception to this rule would be an abandonment of US permanent residency through a tax treaty election, because it would affect the definition of a resident alien under IRC §7701(b).

Contact Sherayzen Law Office for Help with Your FBAR Compliance and FBAR Voluntary Disclosure

Sherayzen Law Office specializes in FBAR compliance and Offshore Voluntary Disclosures that involve prior FBAR noncompliance. We have helped hundreds of US taxpayers around the world with their FBAR issues, and we can hep you!

Contact Us Today to Schedule Your Confidential Consultation!

Form 114 US Person Definition | FBAR Tax Lawyer

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FinCEN Form 114 US Person definition is a highly important component of FBAR and US international tax compliance.  In this essay, I will discuss in detail the FinCEN Form 114 US Person definition and highlight some common issues that arise with respect to this definition.

Form 114 US Person Definition: What is Form 114 and What is its Relation to FBAR ?

FinCEN Form 114, Report of Foreign Bank and Financial Accounts (used to be TD F 90-22.1) is commonly known as FBAR, the Report of Foreign Bank and Financial Accounts. This form is used by US persons to report to the IRS a financial interest in or signatory authority over foreign financial accounts.  This is one of the most important forms that US taxpayers need to file in order to comply with their US international tax law requirements. A failure to file an FBAR when required may result in an imposition of severe IRS penalties.

Form 114 US Person Definition: Only US Persons are Required to File FBARs

It is important to understand that only “US Persons”, as defined by the IRS for the FBAR compliance purposes, are required to file FBARs.  What is the legal basis for this and where does this term “US Person” come from?

BSA (Bank Secrecy Act) §5314(a) states that the Secretary of the Treasury shall require a “resident or citizen of the United States or a person, in, and doing business in, the United States, to keep records, file reports”.  This seems like the FBAR requirement may apply a hugely broad group of people (far beyond US residents and citizens), especially if one takes into account that the “United States” is defined to include all 50 states, the District of Columbia, the territories, and insular possessions of the United States and the Indian lands as defined in the Indian Gaming Regulatory Act. 31 CFR §§1010.350(b) and 1010.100(hhh).  The territories and possessions of the United States include American Samoa, the Commonwealth of the Northern Mariana Islands, the Commonwealth of Puerto Rico, Guam, and the US Virgin Islands (see BSA Electronic Filing Requirements for Report of Foreign Bank and Financial Accounts (FinCEN Form 114), p. 5.).

Despite this initial impression, the actual definition that we use today is much smaller than what is mandated by §5314(a) and it is thanks to BSA §5314(b).  BSA §5314(b) states that the IRS has the discretion to interpret what this provision actually means and who is exempt from the FBAR filing requirement.

Armed with this authority, on February 26, 2010, the IRS issued proposed regulations, which for the first time defined that only “US Persons” needed to file FBARs. This is why we discuss the definition of a US Person when we discuss who is required to file FBARs.

Form 114 US Person Definition: Who is a Person ?

Before we turn to the definition of a “US Person”, we need to discuss who is considered to be a “Person” for the Form 114 purposes. Under 31 CFR §1010.350(b), a “person” includes:  natural persons (US citizens and US residents) and entities, including but not limited to: corporations, partnerships, trusts, or limited liability companies formed under the laws of the United States.  This definition includes entities disregarded for tax purposes (as long as they are US persons).

Additionally, pension and welfare plans are also US entities that need to file FBARs. See Amendment to the Bank Secrecy Act Regulations—Reports of Foreign Financial Accounts, 76 Fed. Reg. 10, 234 (Feb. 24, 2011); IRM 4.26.16.2.1.3(3) (06-24-21).  Even though the regulations do not mention it, the Form 114 instructions expand the “person” definition to estates.  It is important to note that, according to page 6 of the FBAR electronic filing instructions, an executor of an estate has a fiduciary obligation to file FBAR on behalf of the estate and on behalf of the decedent in the year following the decedent’s death.

Form 114 US Person Definition: General Definition of a US Person

The definition of a US person includes the following categories of persons:

(1) US citizens;

(2) residents of the United States;

(3) an entity, such as a corporation, partnership and a limited liability company, created or organized in the United States or under the laws of the United States;

(4) a trust formed under the laws of the United States; and

(5) an estate formed under the laws of the United States.

Let’s analyze each of these categories in more detail.

Form 114 US Person Definition: US Citizens

All US citizens are subject to the FBAR filing requirement, even minor children.  The general definition of a US citizen is contained in 8 USC §1401.

Form 114 US Person Definition: US Residents

All US residents are subject to FBAR filing requirements.  Pursuant to 31 CFR §1010.350(b)(2), the definition of “US residents” follows the definition of a resident alien under §7701(b) with one modification – the definition of the “United States” still follows 1010.100(hhh) described above. Also, see IRM 4.26.16.2.1.2 (11-06-15).

There are three classes of US residents: (1) US permanent residents; (2) persons who satisfied the Substantial Presence Test; and (3) persons who elected to be treated as US residents.  Let’s discuss each of these classes of US residents in more detail.

1.  US Permanent Residents (the “Green Card Test”)

A person is considered a US person if at any time during the calendar year the person has been lawfully granted the privilege of residing permanently in the United States under the immigration laws and such status has not been revoked. 26 USC §§7701(b)(1)(A)(i) and 7701(b)(6).

One of the most common issues occurs when a person has been issued a green card and he has not yet physically entered the United States. In such cases, this person would not be considered as a resident alien until he actually physically enters the United States. 26 USC §7701(b)(2)(A)(ii).  Once he enters the country, however, he becomes a US permanent resident and continues to be one until the green card is revoked or considered abandoned either judicially or administratively. See 26 CFR §301.7701(b)-1(b)(2) and 26 CFR §301.7701(b)-1(b)(3).

2.  Substantial Presence Test

Even if a person is not a US permanent resident, he may still be considered a US Person if he meets the IRC §7701(b)(3) substantial presence test.  In reality, there are two substantial presence tests.

The first substantial presence test is met if a person is physically present in the United States for at least 183 days during the calendar year. 26 USC §7701(b)(3).  The second substantial presence test is met if two conditions are satisfied: (1) the person is present in the United States for at least 31 days during the calendar year; and (2) the sum of the days on which this person was present in the United States during the current and the two preceding calendar years (multiplied by the fractions found in §7701(b)(3)(A)(ii)) equals to or exceeds 183 days. 26 USC 7701(b)(3)(A).

Let’s focus on the mechanics of the second calculation.  The way to determine whether the 183-day test is met is to add: (a) all days present in the United States during the current calendar year (i.e. the year for which you are trying to determine whether the Substantial Presence Test is met) + (b) one-third of the days spent in the United States in the year immediately preceding the current year + (c) one-sixth of the days spent in the United States in the second year preceding the current calendar year. See 26 USC §7701(b)(3).

Note that the Internal Revenue Code (IRC) provides a number of important exceptions to the Substantial Presence Test.  In this article, I am just providing the general rule.

3.  Election to be Treated as a US Resident Alien

A person who makes the first-year election to be treated as a US resident alien pursuant to §7701(b)(4) is a US Person for FBAR purposes.   Note, however, that this rule applies only to elections made under this provision.  A nonresident alien spouse of a US person who makes an election under the IRC §§6013(g) and 6013(h) to be treated as a resident alien will not be considered as a US person for the FBAR compliance purposes.  This is an important divergence between the income tax and FBAR rules.

Form 114 US Person Definition: US Entities, Trusts & Estates

Entities (corporations, partnerships, limited liability companies, et cetera), trusts and estates created, organized or formed in the United States or under the laws of the United States are generally considered to be US Persons for FBAR purposes.

A foreign subsidiary of a US parent will not have any FBAR obligations as long as it is not formed, created or organized under the laws of the United States. However, the US parent company may be required to include the foreign accounts of its foreign subsidiary on its FBAR. 31 CFR §1010.350(e)(2)(ii).

Moreover, a foreign entity organized in and under the laws of a foreign country will not be subject to the FBAR requirements even if it elects to be treated as a US entity for US tax purposes. See Amendment to the Bank Secrecy Act Regulations—Reports of Foreign Financial Accounts, 76 Fed. Reg. 10, 234-238 (Feb. 24, 2011).

Contact Sherayzen Law Office for Professional Help with Your FBAR Compliance

If you need questions concerning your FBAR compliance or a voluntary disclosure concerning your prior FBAR noncompliance, contact Sherayzen Law Office for professional help!  Our firm specializes in FBAR compliance and offshore voluntary disclosures to remedy prior FBAR noncompliance.

We have helped hundreds of clients around the world and we can help you! Contact Us Today to Schedule Your Confidential Consultation!

2022 FBAR Conversion Rates | FBAR Tax Lawyer & Attorney

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The 2022 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 2022 FBAR and 2022 Form 8938 instructions both require that 2022 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 2022 FBAR conversion rates is the default choice, not an exclusive one). In other words, the 2022 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 2022 FBAR conversion rates online (they are called “Treasury’s Financial Management Service rates” or the “FMS rates”).

Since the 2022 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 2022 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 – AFGHANI89.11
ALBANIA – LEK106.5
ALGERIA – DINAR136.467
ANGOLA – KWANZA503.65
ANTIGUA – BARBUDA – E. CARIBBEAN DOLLAR2.7000
ARGENTINA – PESO183
ARMENIA – DRAM400
AUSTRALIA – DOLLAR1.471
AUSTRIA – EURO0.936
AZERBAIJAN – NEW MANAT1.7
BAHAMAS – DOLLAR1.0000
BAHRAIN – DINAR0.3770
BANGLADESH – TAKA105
BARBADOS – DOLLAR2.02
BELARUS – NEW RUBLE2.518
BELGIUM – EURO0.936
BELIZE – DOLLAR2
BENIN – CFA FRANC 614.84
BERMUDA – DOLLAR1
BOLIVIA – BOLIVIANO6.86
BOSNIA – MARKA1.83
BOTSWANA – PULA12.739
BRAZIL – REAL5.286
BRUNEI – DOLLAR1.34
BULGARIA – LEV New1.83
BURKINA FASO – CFA FRANC614.84
BURMA – KYAT2100
BURUNDI – FRANC2045.3
CAMBODIA – RIEL4051
CAMEROON – CFA FRANC613.79
CANADA – DOLLAR1.354
CAPE VERDE – ESCUDO103.16
CAYMAN ISLANDS – DOLLAR0.82
CENTRAL AFRICAN REPUBLIC – CFA FRANC613.79
CHAD – CFA FRANC613.79
CHILE – PESO851.5
CHINA – RENMINBI6.897
COLOMBIA – PESO4845.83
COMOROS – FRANC461.6
CONGO – CFA FRANC613.79
COSTA RICA – COLON591.36
COTE D’IVOIRE – CFA FRANC614.84
CROATIA – KUNA6.87
CROATIA – EURO0.936*
CUBA – Chavito1
CYPRUS – EURO0.936
CZECH REPUBLIC – KORUNA22.102
DEM. REP. OF CONGO – FRANC2012
DENMARK – KRONE6.959
DJIBOUTI – FRANC177
DOMINICAN REPUBLIC – PESO55.72
ECUADOR – DOLARES1.0000
EGYPT – POUND24.74**
EGYPT – POUND29.5**
EL SALVADOR – DOLARES1.0000
EQUATORIAL GUINEA – CFA FRANC613.79
ERITREA – NAKFA15
ESTONIA – EURO0.936
ETHIOPIA – BIRR53.339
EURO ZONE – EURO0.936
FIJI – DOLLAR2.176
FINLAND – EURO0.936
FRANCE – EURO0.936
GABON – CFA FRANC613.79
GAMBIA – DALASI61
GEORGIA – LARI2.665
GERMANY – EURO0.936
GHANA – CEDI9.8***
GHANA – CEDI11.5***
GREECE – EURO0.936
GRENADA – EAST CARIBBEAN DOLLAR2.7
GUATEMALA – QUETZAL7.84
GUINEA – FRANC8554
GUINEA BISSAU – CFA FRANC614.84
GUYANA – DOLLAR215
HAITI – GOURDE145
HONDURAS – LEMPIRA24.552
HONG KONG – DOLLAR7.797
HUNGARY – FORINT374.63
ICELAND – KRONA141.61
INDIA – RUPEE82.599
INDONESIA – RUPIAH15528.42
IRAN – RIAL42000
IRAQ – DINAR1458.53
IRELAND – EURO0.936
ISRAEL – SHEKEL3.518
ITALY – EURO0.936
JAMAICA – DOLLAR150
JAPAN – YEN131.83
JORDAN – DINAR0.708
KAZAKHSTAN – TENGE462.54
KENYA – SHILLING123.25
KOREA – WON1252.61
KOSOVO – EURO0.936
KUWAIT – DINAR0.306
KYRGYZSTAN – SOM85.68
LAOS – KIP17217
LATVIA – EURO0.936
LEBANON – POUND1500
LESOTHO – MALOTI16.948
LIBERIA – DOLLAR153.5
LIBYA – DINAR4.817
LITHUANIA – EURO0.936
LUXEMBOURG – EURO0.936
MADAGASCAR – ARIARY4360
MALAWI – KWACHA1035.49
MALAYSIA – RINGGIT4.4
MALDIVES – RUFIYAA15.42
MALI – CFA FRANC614.84
MALTA – EURO0.936
MARSHALL ISLANDS – DOLLAR1
MAURITANIA – OUGUIYA37
MAURITIUS – RUPEE43.85
MEXICO – PESO19.546
MICRONESIA – DOLLAR1
MOLDOVA – LEU19.08
MONGOLIA – TUGRIK3443.37
MONTENEGRO – EURO0.936
MOROCCO – DIRHAM10.48
MOZAMBIQUE – METICAL 63.24
NAMIBIA – DOLLAR16.948
NEPAL – RUPEE132.25
NETHERLANDS – EURO0.936
NETHERLANDS ANTILLES – GUILDER1.78
NEW ZEALAND – DOLLAR1.575
NICARAGUA – CORDOBA36.15
NIGER – CFA FRANC614.84
NIGERIA – NAIRA440
NORWAY – KRONE9.831
OMAN – RIAL0.385
PAKISTAN – RUPEE226.4
PANAMA – BALBOANot Listed
PANAMA – DOLARES1
PAPUA NEW GUINEA – KINA3.431
PARAGUAY – GUARANI7309.61
PERU – SOL3.786
PHILIPPINES – PESO55.606
POLAND – ZLOTY4.38
PORTUGAL – EURO0.936
QATAR – RIYAL3.64
REP. OF N MACEDONIA – DINAR57.56
REPUBLIC OF PALAU – DOLLAR1
ROMANIA – NEW LEU 4.627
RUSSIA – RUBLE71.481
RWANDA – FRANC1060
SAO TOME & PRINCIPE – NEW DOBRAS23.062
SAUDI ARABIA – RIYAL3.75
SENEGAL – CFA FRANC614.84
SERBIA – DINAR109.69
SEYCHELLES – RUPEE12.87
SIERRA LEONE – LEONE18.8
SINGAPORE – DOLLAR1.34
SLOVAK REPUBLIC – EURO0.936
SLOVENIA – EURO0.936
SOLOMON ISLANDS – DOLLAR7.949
SOMALI – SHILLING565
SOUTH AFRICA – RAND16.948
SOUTH SUDANESE – POUND669
SPAIN – EURO0.936
SRI LANKA – RUPEE363
ST LUCIA – E CARIBBEAN DOLLAR2.7
SUDAN – SUDANESE POUND576
SURINAME – GUILDER31.714
SWAZILAND – LANGENI16.948
SWEDEN – KRONA10.386
SWITZERLAND – FRANC0.923
SYRIA – POUND2510
TAIWAN – DOLLAR30.648
TAJIKISTAN – SOMONI10.16
TANZANIA – SHILLING2329
THAILAND – BAHT34.52
TIMOR – LESTE DILI1
TOGO – CFA FRANC614.84
TONGA – PA’ANGA2.261
TRINIDAD & TOBAGO – DOLLAR6.765
TUNISIA – DINAR3.094
TURKEY – NEW LIRA18.711
TURKMENISTAN – NEW MANAT3.491
UGANDA – SHILLING3715
UKRAINE – HRYVNIA36.569
UNITED ARAB EMIRATES – DIRHAM3.673
UNITED KINGDOM – POUND STERLING0.83
URUGUAY – PESO39.95
UZBEKISTAN – SOM11224.32
VANUATU – VATU119.9
VENEZUELA – BOLIVAR SOBERANO17.236****
VENEZUELA – BOLIVAR SOBERANO19.23****
VENEZUELA – FUERTE (OLD)248832
VIETNAM – DONG23610
WESTERN SAMOA – TALA2.607
YEMEN – RIAL580
ZAMBIA – NEW KWACHA 18.1
ZIMBABWE – RTGS654.66

*Note #1: the official exchange rate for Euro on December 31, 2022 was 0.936; however, with respect to Croatia the Department of the Treasury lists 0.925. We believe that this is a mistake. Please, consult the Department of the Treasury for clarification.

**Note #2: the Treasury Department lists two alternative rates for the Egyptian Pound without clarification which rate should be used for FBAR and Form 8938. We believe that the second rate is correct as it more properly reflects the conversion rate at that time. However, if you wish to follow the safest route, you can use 24.74 conversion rate. Please, consult the Department of the Treasury for clarification.

***Note #3: the Treasury Department lists two alternative rates for the Ghanan Cedi without clarification which rate should be used for FBAR and Form 8938. We believe that the second rate is correct as it more properly reflects the conversion rate at that time. However, if you wish to follow the safest route, you can use 9.8 conversion rate. Please, consult the Department of the Treasury for clarification.

****Note #4: the Treasury Department lists two alternative rates for the Venezuelan Bolivar Soberano without clarification which rate should be used for FBAR and Form 8938. We believe that the second rate is correct as it more properly reflects the conversion rate at that time. However, if you wish to follow the safest route, you can use 17.236 conversion rate. Please, consult the Department of the Treasury for clarification.