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.

2022 Required Minimum Distributions | Tax Lawyer Minneapolis

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On December 12, 2022, the Internal Revenue Service reminded those who were born in 1950 or earlier that funds in their retirement plans and individual retirement arrangements face important upcoming deadlines for the 2022 required minimum distributions to avoid penalties.

What are the 2022 Required Minimum Distributions?

Required minimum distributions, or RMDs, are minimum amounts that many retirement plans and IRA account owners must generally withdraw annually after they reach age 72. Account owners can delay taking their first RMD until April 1 following the later of the calendar year they reach age 72 or, in a workplace retirement plan, retire. RMDs are taxable income and may be subject to penalties if not timely taken.

IRA 2022 Required Minimum Distributions

IRAs: The RMD rules require traditional IRA, and SEP, SARSEP, and SIMPLE IRA account holders to begin taking distributions at age 72, even if they’re still working. Account holders reaching age 72 in 2022 must take their first RMD by April 1, 2023, and the second RMD by December 31, 2023, and each year thereafter.

Roth IRAs do not require distributions while the original owner is alive.

Retirement Plans 2022 Required Minimum Distributions

Retirement Plans: In 401(k), 403(b) and 457(b) plans; profit-sharing and other defined contribution plans; and defined benefit plans, the first RMD is due by April 1 of the later of the year they reach age 72, or the participant is no longer employed (if allowed by the plan). A 5% owner of the employer must begin taking RMDs at age 72. Remember, RMDs may not be rolled over to another IRA or retirement plan.

Who Does the Required Minimum Distributions?

An IRA trustee, or plan administrator, must either report the amount of the RMD to the IRA owner or offer to calculate it. An IRA owner, or trustee, must calculate the RMD separately for each IRA owned. They may be able to withdraw the total amount from one or more of the IRAs. However, RMDs from workplace retirement plans must be taken separately from each plan.

50% tax on the Missed 2022 Required Minimum Distributions

Not taking a required distribution, or not withdrawing enough, could mean a 50% excise tax on the amount not distributed. The IRS has worksheets to calculate the RMD and payout periods.

Special Case: Inherited IRAs

An RMD may be required for an IRA, retirement plan account or Roth IRA inherited from the original owner. Retirement Topics – Beneficiary has information on taking RMDs from an inherited IRA or retirement account and reporting taxable distributions as part of gross income. Publication 559, Survivors, Executors and Administrators, can help those in charge of the estate complete and file federal income tax returns, and explains their responsibility to pay any taxes due on behalf of the decedent or person who has died.

Note on the 2020 Coronavirus-Related Distributions

Since 2020 RMDs were waived, an account owner or beneficiary who received an RMD in 2020 had the option of returning it to their IRA or other qualified plan to avoid paying taxes on that distribution. A 2020 RMD that qualified as a coronavirus-related distribution may be repaid over a 3-year period or have the taxes due on the distribution spread over three years.

A 2020 withdrawal from an inherited IRA could not be repaid to the inherited IRA but may be spread over three years for income inclusion.

Sherayzen Law Office will continue to monitor any news concerning the 2022 RMDs.

2022 Fourth Quarter IRS Interest Rates (Underpayment & Overpayment)

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On August 15, 2022, the IRS announced that the 2022 Fourth Quarter IRS interest rates will again increase for both underpayment and overpayment cases. This increase closely follows the Federal Reserve’s recent increases in interest rates.

This means that, the 2022 Fourth Quarter IRS interest rates will be as follows:

Six (6) percent for overpayments (five (5) percent in the case of a corporation);
Six (6) percent for underpayments;
eight (8) percent for large corporate underpayments; and
three and one-half (3.5) percent for the portion of a corporate overpayment exceeding $10,000.

Under the Internal Revenue Code, the interest rates are determined on a quarterly basis. This means that the next change in the IRS underpayment and overpayment interest rates may occur only for the 1st Quarter of 2023.

The the 2022 Fourth Quarter IRS interest rates are important for many reasons. These are the rates that the IRS uses to determine how much interest a taxpayer needs to pay on an additional tax liability that arose as a result of an IRS audit or an amendment of his US tax return. The IRS also utilizes these rates with respect to the calculation of PFIC interest on Section 1291 tax.

As an international tax law firm, Sherayzen Law Office keeps track of the IRS underpayment interest rates on a regular basis. We often amend our client’s tax returns as part of an offshore voluntary disclosure process. For example, both Streamlined Domestic Offshore Procedures and Streamlined Foreign Offshore Procedures require that a taxpayer amends his prior US tax returns, determines the additional tax liability and calculates the interest on this liability.

Moreover, we very often have to do PFIC calculations for our clients under the default IRC Section 1291 methodology. This calculation requires the usage of the IRS underpayment interest rates in order to determine the amount of PFIC interest on the IRC Section 1291 tax.

Finally, it is important to point out that the IRS will use the 2022 Fourth Quarter IRS interest rates to determine the amount of interest that needs to be paid to a taxpayer who is due a tax refund as a result of an IRS audit or amendment of the taxpayer’s US tax return. Surprisingly, we sometimes see this scenario arise in the context of offshore voluntary disclosures.

Sherayzen Law Office continues to track any changes the IRS makes to its overpayment and underpayment interest rates.

Establishing Cost-Basis in Foreign Real Estate | IRS Audit Tax Lawyer & Attorney

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One of the most challenging issues during an IRS audit is establishing cost-basis in foreign real estate.  This issue most frequently comes up in the context of real estate that was obtained through inheritance or gift many years ago.  In this article, based on my IRS audit experiences, I would like to discuss the main challenges and case strategies associated with establishing the cost-basis in foreign real estate in a manner that would satisfy the IRS during an audit.

An important note: I will not be discussing this issue in the context of an IRS audit of an offshore voluntary disclosure and how it would affect the calculation of an Offshore Penalty.  This essay is strictly limited to an IRS audit that involves US international tax issues without the taxpayer ever going through a voluntary disclosure.

Another important note: this article is written more for the benefit of other international tax lawyers, not the general public.

Establishing Cost-Basis in Foreign Real Estate: Importance

Before we discuss the problems associated with establishing the cost-basis in foreign real estate, we need to first understand why this issue is so important.  There are three main consequences to establishing cost-basis in the context of an IRS audit. 

First, the income tax impact of failure to establish cost-basis in a foreign property on the audited taxpayer may be truly disastrous.  Obviously, if you cannot prove any cost-basis in a property (or you can only convince the IRS that there was minimal cost-basis), you will have to recognize all proceeds from the sale of this property as capital gains (or potentially subpart F income if you owned a property though a foreign corporation).

Second, there is a very important psychological impact on the entire audit if you have a large unreported gain from sale of foreign real estate.  The IRS agent in charge of an audit is likely to take a more aggressive position not only on this issue, but also on other issues irrespective of whether they are directly related to unreported gain.   The most frequent victims of this hardened attitude of an IRS agent are the legal arguments in support of a reasonable cause.

Finally, a large gain from a sale of foreign real estate is likely to encourage the IRS to dig deeper and even expand the audit to more years.  In one of my audit cases, an IRS agent initially believed that there was a large capital gain and expanded the audit to five prior years; however, he reversed this decision once I was able to show that the sold real property had a much higher cost-basis due to numerous improvements that were made by my client over a number of years.

In other words, establishing cost-basis in a sold real estate property may be one of the most crucial issues in an IRS audit.

Establishing Cost-Basis in Foreign Real Estate: Top 3 Challenges

The challenges to establishing cost-basis in foreign real estate are highly dependent on the facts of the case.  However, there are three main themes that usually appear in one form or another in every IRS audit case.

The first challenge is absence of documentation.  This is by far the most common and most important battleground between the IRS and the taxpayer during the vast majority of IRS audits in this area, especially if the direct documentation is absent due to passage of time.

The second challenge is the potential opposition from the IRS to proving cost-basis indirectly through usage of circumstantial evidence and third-parties.

The third challenge is establishing the credibility of evidence. For example, in one of my cases, the IRS initially refused to accept a valuation report prepared by a local professional valuation expert because the report lacked a proper explanation of how he arrived at the proposed values.

Establishing Cost-Basis in Foreign Real Estate: Top 4 Strategies for Overcoming Challenges

There are numerous strategies to deal with the cost-basis establishment challenges. Your choice among them should depend on the facts and circumstances of your case.  Sometimes, you will even come up with a brand-new strategy tailored specifically to the unique challenges of your case.

Nevertheless, there are four common themes to the strategies used in overcoming the aforementioned challenges.  First, you need to recreate the logical history of the property and capital improvements to the property in order to convince the IRS that the valuation your client supplied is logical and reasonable.

Second, demonstrate to the IRS agent in charge of your client’s audit that you are a reliable source of information.  The more objective you appear (and you actually are), the more the IRS sees that you will not allow false facts or statements to enter the record, the more the IRS sees that your client shares both of these traits, the more likely the IRS agent will accept your position or be willing to achieve a compromise with you (see below).

Third, utilize indirect and circumstantial evidence as well as third-party affidavits/testimony to support the valuation of the property.  In other words, if you have no ability to directly establish the cost-basis of a property, then you need to find creative ways to build the necessary records and establish their credibility through usage of supporting documents and/or testimony. 

For example, in one of my previous audits, the client had no documentation whatsoever except one isolated receipt to prove the substantial improvements made to her foreign real estate over the past almost forty (!) years.  My solution to this problem was to first get an affidavit from my client fully stating all improvements made with approximate cost based purely on her memory.  Then, I obtained additional signed statements from neighbors largely supporting the estimates as well as the fact that these improvements were indeed made. Finally, I obtained a statement from a local construction company owner who stated that he recalled these improvements and confirmed the estimated amounts.  Additionally, all of the improvements were properly explained by the history of how the property was obtained, for what purpose and why so many improvements were needed.  All of these facts and circumstances were explained in a letter to the IRS agent together with the legal basis (i.e., case law) showing how courts have accepted similar evidence in the past. Under the weight of this substantial record (and some other circumstances of this case), the IRS finally agreed to accept all improvements as part of an overall compromise.

Finally, use creative legal strategies to convince the IRS to accept a different cost-basis in a property through operation of tax rules.  This is a very complex strategy, but it is more commonly employed than one may believe.  For example, in one of my prior audit cases, the IRS agreed to disregard the foreign corporation that owned the foreign property allowing the stepped-up basis for this inherited property.

Contact Sherayzen Law office for Professional Help with IRS Audits Involving Foreign Real Estate

If you have foreign assets and you are audited by the IRS, contact Sherayzen Law Office for professional help.  We have helped hundreds of US taxpayers around the world to bring their tax affairs in full compliance with US tax laws, including during IRS audits.  We can help you!

Contact Us Today to Schedule a Confidential Consultation!

Tax Residency Starting Date | International Tax Lawyer & Attorney

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In situations where a person was not classified as a resident alien at any time in the preceding calendar year and he became a resident alien at some point during current year, a question often arises concerning the tax residency starting date of such a person. This article seeks to provide a succinct overview of this question in three different contexts: US permanent residence, substantial presence test and election to be treated as a tax resident.

Tax Residency Starting Date: General Rule for Green Card Holders

Pursuant to IRC (Internal Revenue Code) §7701(b)(2)(A)(iii), the starting tax residency date for green card holders is the first day in the calendar year in which he or she is physically present in the United States while holding a permanent residence visa.  However, if the green card holder also satisfies the Substantial Presence Test prior to obtaining his green card, the tax residency is the earliest of either the green card test described in the previous sentence or the substantial presence test (see below).

Tax Residency Starting Date: General Rule for the Substantial Presence Test

Generally, under the substantial presence test, the tax residence of an alien starts on the first day of his physical presence in the United States in the year he met the substantial presence test. See IRC §7701(b)(2)(A)(iii).  For example, if an alien meets the requirements of the Substantial presence test in 2022 and his first day of physical presence in the United States was March 1, 2022, then his US tax residency started on March 1, 2022.

Tax Residency Starting Date: Nominal Presence Exception & the Substantial Presence Test

A reader may ask: how does the rule described above work in case of a “nominal presence” in the United States. IRC §7701(b)(2)(C) provides that, for the purposes of determining the residency starting date only, up to ten (10) days of presence in the United States may be disregarded, but only if the alien is able to establish that he had a “closer connection” to a foreign country rather than to the United States on each of those particular ten days (i.e., all continuous days during a visit to the United States may be excluded or none of them). There is some doubt about the validity of this rule, but it has never been contested in court as of the time of this writing.

This rule may lead to a paradoxical result.  For example, if X visits the United States between March 1 and March 10 and leaves on March 10; then later comes back to the United States on May 1 of the same year and meets the substantial presence test, then he may exclude the first ten days in March and his US tax residency will start on May 1.  If, however, X prolongs his visit and leaves on March 12, then none of the days will be excluded (since March 11 and 12 cannot be excluded under the rules) and his US tax residency will commence on March 1.

I want to emphasize that the nominal presence exception only applies in determining an alien’s residency starting date. It is completely irrelevant to the determination of whether a taxpayer met the Substantial Presence Test; i.e. the days excluded under the nominal presence exception are still counted toward the Substantial Presence Test calculation.

Tax Residency Starting Date: Additional Requirements for Nominal Presence Exception & Penalty for Noncompliance

The IRS has imposed two additional requirements concerning claiming “nominal presence” exclusion (again, both of them have questionable validity as there is nothing in the statutory language about them).  First, the alien must show that he had a “tax home” in the same foreign country with which he has a closer connection.

Second, Treas. Regs. §301.7701(b)-8(b)(3) requires that an alien who claims the nominal presence exception must file a statement with the IRS as well as attach such statement to his federal tax return for the year in which the termination is requested. The statement must be dated, signed, include a penalty of perjury clause and contain: (a) the first day and last day the alien was present in the United States and the days for which the exemption is being claimed; and (b) sufficient facts to establish that the alien has maintained his/her tax home in and a closer connection to a foreign country during the claimed period. Id.

A failure to file this statement may result in an imposition of a substantial penalty: a complete disallowance of the nominal presence exclusion claim.  Since IRC §7701(b)(8) does not contain the requirement to file any statements with the IRS to claim the nominal presence exception, the penalty stands on shaky legal grounds.  However, as of the time of this writing, there is no case law directly on point.

Additionally, as almost always in US international tax law, there are exceptions to this rule.  First, if the alien shows by clear and convincing evidence that he took: (a) “reasonable actions” to educate himself about the requirement to properly file the statement and (b) “significant affirmative actions” to comply with this requirement, then the IRS may still allow the nominal presence exclusion claim to proceed. Treas. Regs. 301.7701(b)-8(d). 

Second, under Treas. Regs. §301.7701(b)-8(e), the IRS has the discretion to ignore the taxpayer’s failure to file the required nominal presence statement if it is in the best interest of the United States to do so.

Tax Residency Starting Date: Election to Be Treated as a US Tax Resident

In situations where a resident alien elects to be treated as a US tax resident (for example, by filing a joint resident US tax return with his spouse), the tax residency date starts on the first day of the year for which election is made.  See Treas. Regs. §7701(b)(2)(A)(iv).

Contact Sherayzen Law Office for Professional Help with US International Tax Law, Including the Determination of the Tax Residency Starting Date

If you have foreign assets or foreign income or if you are trying to determine your tax residency status in the United States, contact Sherayzen Law Office for professional help.  Our law firm is a leader in US international tax compliance; we have helped hundreds of US taxpayers around the world and we can help you!

Contact Us Today to Schedule Your Confidential Consultation!