Foreign Taxation

With the influx of inpatriate students and workers in the technology and electronics industries, The Tax Practice has served non-resident, resident alien and duel-status clients since 1999.  The firm prepares non-resident tax returns and provides advice and counsel regarding residency testing, treaty benefits, totalization agreements, disclosure, non/resident elections, foreign tax credits, foreign income exclusions, exempt income, and sailing permits.

Clients terminating their US residency/alien registration card (aka green card) after June 3, 2004 fall under additional filing obligations to preclude annual US tax exposure after returning to their country of citizenship.  The Tax Practice advises clients on required documentation and offers preparation of initial and annual expatriation information filings.

U.S. taxpayers are required to report their worldwide income; that is, income from both U.S. and foreign sources.  In addition, taxpayers who have interest in, or signature authority over, a financial account in a foreign country – such as a bank account, securities account, or other financial account – are required to file Form 114, Report of Foreign Bank and Financial Accounts, if the aggregate value of all such financial accounts exceeds $10,000 at any time during the calendar year.  Form 114 is not filed with your tax return.  It is filed with the Department of the Treasury in Detroit, Michigan, no later than June 30 of the year following the calendar year reported.  Timely filed disclosures must be received  at the Treasury Department by June 30th.  Failure to report income in foreign bank accounts or to timely file the form carries serious consequences, including large monetary penalties, and in some cases, criminal penalties.  The Tax Practice consults with clients on specific 114 filing obligations and prepares 114 disclosures.

The Tax Practice also advise clients (US citizens) working abroad on matters relating to filing and reporting requirements, currency translation accounting, foreign tax deductions/credits and foreign income exclusions.

To assist taxpayers with foreign country tax matters, please visit Country Specific Tax Sites.