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FinCEN Form 114 Indian Financial Accounts Obligations | FBAR Attorney

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FinCEN Form 114, the Report of Foreign Bank and Financial Accounts, commonly known as  “FBAR”, is one of the most important requirements that Indian Americans face as part of their US tax compliance concerning their Indian Financial Accounts. This articles provides an overview of the  Indian American’s FBAR compliance requirements with the particular focus on the FinCEN Form 114 Indian Financial Accounts obligations.

FinCEN Form 114 Indian Financial Accounts: FBAR Background Information

FinCEN Form 114 is a critical requirement for any US person with financial accounts outside the United States. US citizens, residents, and even certain non-residents who have a financial interest or signature authority over foreign financial accounts must file an FBAR if the aggregate value of these accounts exceeds $10,000 at any time during the calendar year.

FBAR was introduced in the early 1970s as part of the Bank Secrecy Act.  Its original purpose was to combat money laundering, tax evasion, and other illicit activities involving undisclosed foreign financial assets. After the 9/11 terrorist attacks, however, Congress turned over the FBAR enforcement to the IRS, effectively turning FBAR into a tax form and one of the most formidable enforcement tools in the IRS arsenal.

What makes FinCEN Form 114 such a great US international tax enforcement weapon is the combination its broad scope of compliance, its low reporting threshold and, most importantly, its draconian noncompliance penalties.  FBAR penalties range from criminal penalties (i.e. a person can actually go to jail for FBAR noncompliance in certain limited circumstances) to horrendous civil willful penalties (imposed on a per account per year basis) to even non-willful penalties.  

While the Supreme court limited in 2023 the non-willful penalties to $10,000 (as adjusted for inflation) per form, FBAR has a statute of limitations of six years. This means that a non-willfulness penalty assessed after January 25, 2024 (until sometime at the end of the January of 2025) can still total $96,702 (inflation is accounted for in this number through the end of 2024).

FinCEN Form 114 Indian Financial Accounts: FBAR’s Broad Definition of “Account”

I mentioned above that the broad scope of FBAR compliance is one of the form’s characteristics that makes it so dangerous. The foundation for the far reach of the form stems from the FBAR’s broad definition of what constitutes a reportable “account” “Account” can be applied a huge variety of financial arrangements including but not limited to:

  • Bank accounts (such as savings and checking accounts)
  • Fixed-deposit accounts (each one individually is a separate account)
  • Mutual funds
  • Pension accounts (including the Indian PPF accounts)
  • Insurance policies with a cash-surrender value
  • Precious metal accounts
  • Retirement accounts

Basically, any type of a arrangement that involves a fiduciary relationship with a financial institution (which is itself a term of art with a broad definition) with respect to your assets immediately raises a possibility of additional FinCEN Form 114 compliance.  

It is crucial to note that the FBAR filing requirement applies not only to accounts where a US person is the sole owner but also to accounts where they have joint ownership or signature authority. Even accounts where a person only has signing authority, such as an employer’s account, are subject to the FinCEN Form 114 reporting requirement if the $10,000 threshold is met.

FinCEN Form 114 Indian Financial Accounts: Special Challenges in the Context of India

In the specific context of Indian Financial Accounts, such a broad definition of accounts for FinCEN Form 114 purposes leads to unique compliance challenges. Let’s discuss the three most common challenges. First of all, Indian FBAR filers tend to have a very large number of fixed-deposit and Indian mutual fund accounts as long-term savings financial vehicles. Many Indians think that they only have to report only main checking and savings bank accounts.  This is an important error. FBAR filers need to disclose each fixed-deposit and mutual fund account individually.

Second, Indian FinCEN Form 114 filers generally do not think of life insurance policies as something that they need to disclose.  Yet, the FBAR requires the disclosure of each life insurance policy individually.

Third, FBAR filers must disclose Public Provident Fund (“PPF”) accounts on their FBARs.  Many Indian Americans completely forget about these accounts.

I should also mention one more important point about these unique challenges – income tax compliance concerning all of these accounts that many Indian FBAR filers tend to overlook. India has a very different system of taxation from the United States and, usually, a failure to disclose accounts properly on FBAR is also a good indicator of potential US income tax noncompliance.

FinCEN Form 114 Indian Financial Accounts: Offshore Voluntary Disclosure

Now that we have identified the problem, let’s discuss how to best deal with FinCEN Form 114 noncompliance.  First of all, this is an issue that you should discuss with an international tax attorney who can advise on the best course of action based on the specific facts of your case.

One of the common advices that you will receive from your international tax attorney is to engage in an Offshore Voluntary Disclosure option. Offshore Voluntary Disclosure is a reflection of the fact that the IRS cannot possibly audit every single US income tax return. Hence, the IRS offers various offshore voluntary disclosure programs that allow noncompliant US taxpayers to come forward and report their unreported foreign financial accounts and other foreign assets in exchange for a more lenient treatment.

An offshore voluntary disclosure can be a highly-beneficial solution for prior noncompliance. At the same time, it is a highly-complex process that requires extensive knowledge of US tax laws.

Moreover, in the context of FinCEN Form 114 Indian Financial Accounts noncompliance, there are specific challenges that arise from the income tax treatment concerning Indian fixed-deposit accounts as well as Indian mutual fund investments (something that I alluded to above).

In these situations, working with an experienced international tax attorney who understands the intricacies of US tax reporting of Indian financial accounts is crucial. An attorney can help you navigate the voluntary disclosure process and minimize your exposure to penalties.

Contact Sherayzen Law Office for Professional Help with Your FinCEN Form 114 Indian Financial Accounts Compliance

Sherayzen Law Office is a premier US international tax law firm that specializes in FBAR compliance and offshore voluntary disclosures. We have an extensive experience with US tax reporting concerning Indian bank and financial accounts, including in the context of various offshore voluntary disclosure options such as Streamlined Domestic Offshore Procedures, Streamlined Foreign Offshore Procedures, Delinquent FBAR Submission Procedures, Delinquent International Information Return Submission Procedures, Reasonable Cause disclosures, et cetera. By working with Sherayzen Law Office, you ensure that your compliance with US tax laws is handled thoroughly and professionally with the goal of protecting you from potential penalties.

Contact Sherayzen Law Office today to schedule your confidential consultation!

2024 FBAR Civil Penalties | FBAR International Tax Lawyer & Attorney

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This article is an update of prior articles on the FBAR Civil Penalties. Since the US Congress mandated the IRS to adjust FBAR civil penalties for inflation on an annual basis, this article discusses the year 2024 FBAR Civil Penalties.

2024 FBAR Civil Penalties: Overview of the FBAR Penalty System

FinCEN Form 114, the Report of Foreign Bank and Financial Accounts (commonly known as “FBAR”), has always had a very complex, multi-layered system of penalties, which has grown even more complicated over the years. These penalties can be grouped into four categories: criminal, willful, non-willful and negligent.

Of course, the most dreaded penalties are FBAR criminal penalties. Not only is there a criminal fine of up to $500,000, but, in some cases, a person can be sentenced to 10 years in prison for FBAR violations (and these two criminal penalties can be imposed simultaneously). Since the focus of this article is on FBAR civil penalties.

The next category of penalties are FBAR civil penalties imposed for the willful failure to file an FBAR. These penalties are imposed per each violation – i.e. on each account per year, potentially going back six years (the FBAR statute of limitations is six years).

The third category of penalties are FBAR penalties imposed for a non-willful failure to file an FBAR or a filing of an incorrect FBAR. These penalties can be imposed on US persons who do not even know that FBAR exists.

Finally, with respect to business entities, a penalty can be imposed for a negligent failure to file an FBAR or a filing of an incorrect FBAR.

It is important to note that FBAR has its own reasonable cause exception that may be used to fight the assessment of any of the aforementioned civil penalties. Moreover, each of these penalty categories has numerous levels of penalty mitigation that a tax attorney may utilize to lower his client’s FBAR civil penalties.

2024 FBAR Civil Penalties: Penalties Prior to November 2 2015

Prior to November 2, 2015, FBAR penalties were not adjusted for inflation and stayed flat at the levels mandated by Congress. Let’s go over each category of penalties prior to inflation adjustment.

As of November 1, 2015, Willful FBAR penalties were up to $100,000 or 50% of the highest balance of an account, whichever is greater, per violation. Again, a violation meant a failure to correctly report an account in any year. Non-willful FBAR penalties were up to $10,000 per violation per year; per US Supreme Court’s decision last year, the penalty should have been imposed on a per form (not per account) basis. Finally, FBAR penalties for negligence were up to $500 per violation; if, however, there was a pattern of negligence, the negligence penalties could increase ten times up to $50,000 per violation.

2024 FBAR Civil Penalties: Inflation Adjustment

The situation changed dramatically in 2015. As a result of the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015 (“2015 Inflation Adjustment Act”), Congress mandated federal agents to: (1) adjust the amounts of civil monetary penalties with an initial “catch-up” adjustment; and (2) make subsequent annual adjustments for inflation. The inflation adjustment applied only to civil penalties.

The “catch-up” adjustment meant a huge increase in penalties, because federal agencies were required to update all of these penalties from the time of their enactment (or the last year Congress adjusted the penalties) through November of 2015. This meant that, in 2015, the penalties jumped to account for all accumulated multi-year inflation. The catch-up adjustment was limited to two and a half times of the original penalty.

Fortunately, the Congress adjusted FBAR penalties in 2004 and the “catch-up” adjustment did not have to go back to the 1970s. It still meant a very large (about 25%) increase in FBAR civil penalties, but it was not as dramatic as some other federal penalties.

2024 FBAR Civil Penalties: Bifurcation of FBAR Penalty System

The biggest problem with the inflation adjustment, however, was the fact that it further complicated the already dense multi-layered FBAR system of civil penalties – FBAR penalties became dependent on the timing of a violation and IRS penalty assessment. In essence, the 2015 Inflation Adjustment Act split the FBAR penalty into two distinct parts.

The first part applies to FBAR violations that occurred on or before November 2, 2015. The old pre-2015 FBAR penalties described above applies to these violations irrespective of when the IRS actually assesses the penalties for these violations. The last FBAR violations definitely eligible for the old statutory penalties are those that were made concerning 2014 FBAR which was due on June 30, 2015. The statute of limitations for the 2014 FBAR ran out on June 30, 2021.

The second part applies to all FBAR violations that occurred after November 2, 2015. For all of these violations, the exact amount of penalties will depend on the timing of the IRS penalty assessment, not when the FBAR violation actually occurred. In other words, if an FBAR violation occurred on October 15, 2017 and the IRS assessed FBAR penalties June 17, 2021, the IRS would use the inflation-adjusted FBAR penalties as of the year 2021, not October 15, 2017.

2024 FBAR Civil Penalties: Penalties Assessed On or After January 25, 2024

Now that we understand the history of FBAR penalties, we can specifically discuss the 2024 FBAR Civil penalties. The first thing to understand is that we are talking about penalties assessed by the IRS on or after January 25, 2024; prior to that date, the 2023 FBAR civil penalties were still effective.

The 2024 Willful FBAR penalty imposed under 31 U.S.C. §5321(a)(5)(C)(i)(I) is $161,166 per violation. Per last year’s court decisions, the term “violation” in the context of willful FBAR penalties means on a “per account for each year” basis described above.

The 2024 Non-Willful FBAR penalty imposed under 31 U.S.C. §5321(a)(5)(B) is $16,117 per violation. The term “violation” in the context of non-willful FBAR penalties at this point has been settled to mean “per form” (rather than per-account) basis.

The 2024 Negligence FBAR penalty imposed under 31 U.S.C. §5321(a)(6)(A) is $1,394; if there is a pattern of negligence under 31 U.S.C. §5321(a)(6)(B), then the penalty goes up to $108,489.

Contact Sherayzen Law Office for Professional Help With Your Prior FBAR Noncompliance

Sherayzen Law Office is a leader in US international tax law and FBAR compliance. We have successfully helped hundreds of clients from over eighty countries resolve their prior FBAR noncompliance, including through various voluntary disclosure programs (such as Streamlined Domestic Offshore Procedures, Streamlined Foreign Offshore Procedures, Delinquent FBAR Submission Procedures, et cetera). We can help you!

Contact Us Today to Schedule Your Confidential Consultation!

Singapore Solution Fraud Scheme Co-Creator Pleads Guilty |  SDOP lawyer Minneapolis

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On December 21, 2023, the IRS and the US Department of Justice announced that Mr. Rolf Schnellmann, a Swiss national, pleaded guilty to conspiring to defraud the United States for his role in the creation and implementation of a fraud scheme related to foreign accounts and foreign income called “Singapore Solution”.  In this small essay, I will discuss the Singapore Solution, the facts of the Schnellmann case and the lessons one can draw from this case.

Singapore Solution: Basic Description of the Tax Evasion Scheme

The idea behind the Singapore Solution is fairly simple. Funds owned secretly (i.e. without a proper disclosure to the IRS on FBAR, Form 8938, et cetera) by US persons in a Swiss bank are first transferred to a series of nominee accounts in other jurisdictions (for example, Hong Kong). In the meantime, the Swiss bankers established (usually indirectly through a law firm) a Singapore-based asset management firm which opens new bank accounts in its name in the Swiss bank. After passing through nominee accounts, the US-owned funds are returned to the Swiss bank and placed in the new bank accounts opened by the asset management firm.

In other words, the Singapore Solution basically represents a circular scheme where the ownership of funds is artificially obscured by involvement of third parties. Obviously, the US owners of the undisclosed funds handsomely compensated the Swiss bankers, the managers of the asset management firm and the nominees for their work. Also obviously, this scheme crosses the line between asset/tax planning and criminal tax evasion.

Singapore Solution: Basic Facts of Schnellmann Case

According to court documents and statements made in court, Rolf Schnellmann was the head of Allied Finance Trust AG, a Zurich-based financial services company and a subsidiary of the Allied Finance Group in Liechtenstein.  Between 2008 to 2014, Schnellmann and his co-conspirators helped high-net-worth US taxpayers set-up and implement the Singapore Solution concerning their undeclared bank accounts at Privatbank IHAG Zurich AG (IHAG), a Swiss private bank. 

According to the Department of Justice, Schnellmann and his colleagues transferred more than $60 million from the US-owned undeclared IHAG bank accounts through a series of nominee accounts in Hong Kong and other locations before returning the funds to newly opened accounts at IHAG in the name of a Singapore-based asset-management firm that Schnellmann helped establish. IHAG participated in the 2013 IRS Voluntary Disclosure Program for Swiss Banks. Surely, as a result of this process, IHAG disclosed a lot of information concerning the Singapore Solution.  This allowed the IRS to track down not only the noncompliant US clients of that bank, but also the Singapore Solution creators and facilitators, like Mr. Schnellamann.  He was arrested in August of 2023 in Italy and extradited to the United States.

The IRS Criminal Investigation (IRS-CI) conducted the investigation with the help of the US Justice Department’s Office of International Affairs, Interpol, Italian law enforcement authorities, the Prosecutor General’s Office of Trieste and the Italian Ministry of Justice.

Singapore Solution: Consequences of the Guilty Plea for Schnellmann

As a result of the guilty plea, Mr. Schnellmann is scheduled to be sentenced on July 19, 2024. He now faces a maximum penalty of five years in prison, a period of supervised release, restitution and monetary penalties.

Singapore Solution: Lessons

The Schnellmann case and the Singapore Solution that he co-authored allow us to deduce certain lessons.  The first and most obvious, one must respect the difference between legitimate even if aggressive tax planning and criminal tax evasion.  Mr. Schnellmann crossed that line and will pay a high price for it.

Second, US taxpayers must declare their foreign accounts to the IRS on FBAR, Form 8938 and Schedule B of Form 1040.  Failure to do so may bring very painful consequences in the form of high IRS civil and even criminal penalties.

Finally, there is really no safe place for noncompliant taxpayers to hide. Even if they have been lucky to avoid IRS detection of their noncompliance so far, a disclosure from third parties may lead to an IRS investigation that may ultimately result in the discovery of the noncompliance.  In this case, the IRS will most likely impose very heavy penalties for noncompliance (made even heavier by the fact that the IRS had to invest a lot of resources and man-hours into the case).

Contact Sherayzen Law Office for Professional Help With the Voluntary Disclosure of Your Undisclosed Foreign Assets and Foreign Income

For all of these reasons, noncompliant taxpayers should explore their offshore voluntary disclosure options before the IRS finds out about their noncompliance. Otherwise, an IRS audit will make it impossible for them to lower their IRS noncompliance penalties through a voluntary disclosure.

Sherayzen Law Office is a leader in the IRS offshore voluntary disclosures, including disclosures that involve foreign income noncompliance and foreign asset reporting noncompliance (on FBAR, Form 8938, 3520, 3520-A, 5471, 8865, 8858, et cetera).  Led by Mr. Eugene Sherayzen, a highly-experienced international tax attorney, our international tax team has helped hundreds of US taxpayers around the globe to bring their tax affairs into full compliance with the IRS while lowering and sometimes even eliminating IRS penalties.

Contact Us Today 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.

Happy New Year 2024 From International Tax Law Firm Sherayzen Law Office!!!

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Dear clients, followers, readers and colleagues:

Mr. Eugene Sherayzen, an international tax attorney, and the entire international tax team of Sherayzen Law Office, Ltd. wishes you a very Happy New Year 2024!!!

Dear clients and prospective clients, in the New Year 2024, you can continue to rely on Sherayzen Law Office for:

  1. Resolution of your prior FBAR, FATCA and other US international tax noncompliance through offshore voluntary disclosure, including Streamlined Domestic Offshore Procedures (SDOP), Streamlined Foreign Offshore Procedures (SFOP), Delinquent FBAR Submission Procedures, Delinquent International Information Return Submission Procedures, IRS Voluntary Disclosure Practice and Reasonable Cause Disclosures;
  2. Help with your IRS audits and examination, including audits of: your prior SDOP and SFOP submissions (as well as other voluntary disclosure options) and your annual international tax compliance. We can also help you fight the imposition of IRS penalties for prior international tax noncompliance, including FBAR penalties, Form 8938 penalties, Form 3520 and 3520-A penalties, Form 5471 penalties, Form 5472 penalties, Form 8865 penalties, Form 926 penalties, et cetera;
  3. Preparation of your annual US international tax compliance, including the reporting of foreign income and preparation of FBAR, FATCA Form 8938 and other US international tax compliance forms such as: Forms 3520, 3520-A, 5471, 8621, 8865, 8938 and 926 and
  4. Your international tax planning (inbound and outbound), including individual and business tax planning, We intend to continue to help US firms with conducting business overseas, US owners of foreign businesses and foreign businesses who wish to expand their presence to the United States (including real estate investors).

In resolving all of your current US international tax issues, we will continue to employ ethical creativity, diligence, professionalism and many years of experience with helping other clients. We will also continue to utilize an individual, customized approach, understanding each client’s particular situation.

In 2024, the US international tax compliance requirements will likely grow even more complex, detailed and extensive. The IRS will continue to demand more and more information from US taxpayers, employing its expanding number of revenue agents to enforce US tax laws across the globe and especially in the United States.

In order to deal with this ever-increasing US tax compliance burden, you will need the professional help of Sherayzen Law Office. In this New Year 2024, we can help you!

Your professional US international tax help is but a phone call away from you! Contact us today to schedule a confidential consultation in this New Year 2024!

HAPPY NEW YEAR 2024 EVERYONE!!!