The sourcing of income has very important tax consequences for U.S. and foreign taxpayers.  The IRS taxes U.S. taxpayers on all income, from any source derived; however, U.S. taxpayers will be relieved of double taxation and may utilize the foreign tax credit in many circumstances involving non-purely domestic taxation. Foreign taxpayers, on the other hand, [...]

On February 8, 2011, the Internal Revenue Service announced that a new special voluntary disclosure initiative, designed to bring offshore money back into the U.S. tax system and help people with undisclosed income from hidden offshore accounts get current with their taxes, will be available through August 31, 2011. The IRS decision to open a [...]

Although there is a general misconception that U.S. citizens can relinquish their citizenship in order to escape high U.S. taxes, most of the time this is not true. If you are contemplating such a move, it is essential to understand the basic rules relating to expatriation for purposes of tax avoidance, as the taxes and [...]

FBAR filing is required only if the aggregate balances of a U.S. person’s foreign financial accounts exceed $10,000. Despite appearances, the requirement that the aggregate value of all of the foreign financial accounts exceeds $10,000 at any time during a calendar year is not without complications. In order to figure out the account value in [...]

In this article, I will discuss five most important issues that you need to know before you sign a fee agreement with international tax lawyers in Minneapolis. * How is the international tax lawyer’s fee paid? There are three main models of payment that lawyers use: hourly fee, contingency fee, and flat fee. The hourly [...]

The FBAR must be filed by June 30 of each relevant year, including this year (2010).

U.S. citizens and resident aliens (for U.S. tax purposes) who have financial interest in Canadian Registered Retirements Savings Plans RRSPs)and/or Registered Retirement Income Funds (RRIFs) must report their RRSP and RRIF income to the IRS by using Form 8891. The taxpayers (even if resident aliens from Canada) must comply with this reporting requirement even if [...]

Since October of 2008, the definition of a “U.S. person” has been going through a turbulent phase of uncertainty with periodic expansions and retractions. The pre-2008 FBAR instructions (dating back to July of 2000 version) defined the “U.S. person” broadly as: “(1) a citizen or resident of the United States, (2) a domestic partnership, (3) [...]

It is with pleasure that Sherayzen Law Office announces that on May 5, 2010, Eugene Sherayzen became a Legal Advisor to the Bright New Ideas (“BNI”), a Minnesota non-profit corporation devoted to the alleviation of worldwide poverty through the use of solar energy. In his new capacity, Mr. Sherayzen will help overview the BNI’s U.S. [...]

On December 9, 2009, the U.S. House of Representatives approved H.R. 4213, the “Tax Extenders Act of 2009.” The bill would extend for one more year more than forty tax provisions that are set to expire at the end of this year, including the research credit and a number of important tax breaks for individuals. [...]