To be reportable, the foreign financial account must be physically located outside of the U.S. For example, a financial account maintained in a foreign branch of a U.S. bank is treated as a foreign financial account subject to reporting.
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Conversely, an account maintained in a U.S. branch of a foreign bank is not a foreign financial account subject to reporting.
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Dividends from publicly traded foreign companies get the 15% rate, but taxpayers are now limited to that rate in claiming the foreign tax credit: If a foreign country withholds a 30% tax, you only get a credit against your U.S. tax bill for half of it.
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CDC, for instance, cannot sell its Satyam Infoway shares on either a foreign or a local stockmarket.
But must you file an FBAR even if the only foreign account you have is at a foreign branch of a U.S. bank?
If the client funds are reported on a foreign brokerage statement, we consider this a foreign bank account to be reported under FBAR.
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When he entered the Knesset in 1973 many thought him dull and boorish, and were surprised that he made a decent Speaker and, in 1980, a foreign minister with a genuine and knowledgeable interest in foreign affairs.
The Foreign Agents Registration Act (FARA) requires any agent of a foreign principal - including agents of foreign states, political parties, corporations, non-governmental organizations and even individuals - to register with the U.S. Department of Justice as a foreign agent.
The idea is that you sell a foreign currency call option and use the proceeds of the sale to purchase a foreign currency call option in the same currency with the same counterparty and the same expiration date.
This rule also permits a group to centralize its foreign finance function in a foreign subsidiary, which can receive interest on loans made to related foreign affiliates without U.S. taxation.
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This would result in double taxation of foreign earnings that are also taxed by a foreign country, but foreign taxes generally can be claimed as a credit against U.S. taxes on foreign earnings.
Will the American forces that are still participating be under foreign -- a foreign commander?
Whether it's a foreign language or a new sport, we don't get good at things overnight.
In addition, many Croatians seem more inclined to trust a foreign bank than a domestic one.
Failing to report income or disclose the existence of a foreign account on a tax return is serious.
She was as beautiful as someone in a foreign movie, a book, or a catalogue of strange, expensive clothes.
"If a foreign national marries a British national they have to apply to stay in the UK, " she explained.
Never use a foreign phrase, a scientific word, or any kind of jargon if you can think of an English equivalent.
Never use a foreign phrase, a scientific word or a jargon word if you can think of an everyday English equivalent.
As a young assistant director, Kurosawa attended a double feature where a foreign movie and a Japanese one were shown together.
Borrowing in a foreign currency is a problem if debt costs rise because the currency used to pay that debt is weakening.
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If you are eligible to work in a foreign country, a career in forex can bring the added excitement of living abroad.
'It's one thing if I'm, say, Boeing, and I decide to manufacture in a foreign country on a consensual basis for purely commercial reasons.
It has given Sweden a foreign minister, a Davis Cup player and Raoul Wallenberg, a hero of the second world war who rescued Hungarian Jews.
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One guideline asks charities to determine whether the bank of a foreign recipient of a donation is a shell and whether it has anti-money-laundering controls in place.
This is one of the few industries for which operating at the nanoscale is not a foreign concept as a DNA molecule is roughly 2 nm wide.
That it is, after all, possible to overcome political resistance to a foreign takeover of a big Italian financial institution will provide some small cheer to investors.
Acquiring a foreign company brings a different set of challenges.
But in their current excited state, many in the oil market are wondering whether the attack on a foreign compound heralds a bigger one on a production facility.
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They are accused of conspiracy to act as unlawful agents of a foreign government, a crime less serious than espionage but which carries up to five years in prison.
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