Report on Foreign Bank and Financial Accounts (FBAR): General Requirements

Under the Bank Secrecy Act, each United States person must file a Report of Foreign Bank and Financial Accounts (the “FBAR”) with the U.S. Department of Treasury if two conditions apply. The first condition is that the U.S. person must have either a financial interest in or signature authority (or other comparable authority)over one or [...]

Significance of Income Source Rules in International Tax Law

When dealing with the international transactions, the United States tax law usually divides income into two broad categories: foreign source income and the U.S. source income.  The determination of whether the income is foreign or U.S. in origin depends on a set of rules – the source-of-income rules – created by Congress, elaborated by the [...]