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Entries by Ryan Miller, Katherine Malarsky

Section 987 Regulations: Terminology Explained

Posted 4:00 AM by
As a follow up to our “Section 987 Regulations: Key Considerations,” this blog post will help define many of the complex terms included within these regulations. The regulations relate to the methods a taxpayer must use to account for fluctuations in the foreign currency exchange rates when they have business operations that are denominated in a functional currency different than their own.
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International Tax Issues Update: What You Need to Know

Posted 4:00 AM by
There are a couple of changes related to businesses required to file Form 8938 (when they were previously exempt) and individuals who are not eligible for U.S. Social Security Numbers needing to renew their Individual Taxpayer Identification Number (ITIN) numbers that impact the 2016 filing season.
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Section 987 Regulations: Key Considerations

Posted 4:00 AM by
At long last (after 25 years), on Dec. 7, 2016, the Treasury and Internal Revenue Service (IRS) issued final and temporary regulations under Internal Revenue Code Section 987. These regulations replace the previously proposed 1991 regulations as well as the previously proposed 2006 regulations.
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With Foreign Investment, It's Both “Buyer Beware” and “Seller Beware”

Posted 1:16 PM by
The Association of Foreign Investors in Real Estate’s (AFIRE) annual foreign investment survey reported that 64 percent of respondents intend to increase U.S. investment in real estate in 2016. Data collected by Real Capital Analytics Inc. indicates that foreign purchases of U.S. real estate leapt from less than $5 billion in completed deals in 2009 to $87.3 billion of completed deals in 2015.
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Deadline to Complete the 2015 FBAR Approaching

Posted 4:00 AM by
Any U.S. person that has a financial interest in or signature authority over a foreign financial account—including a bank account, brokerage account, mutual fund, trust, or other type of foreign financial account—may be required to report those accounts and balances to the Department of Treasury’s Financial Crimes Enforcement Network (FinCen). 
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