Sample International Tax Cases

Representative Offshore Voluntary Disclosure Cases

Client is a dual citizen of United States and Switzerland. 2012 OVDP voluntary disclosure required extensive default-method 1291 fund PFIC method calculations and preparation of Forms 5471.

Client is a U.S. citizen residing in Europe. Modified voluntary disclosure involved complex foreign income classification issues, preparation of multiple Forms 5471 and 8865 for the ownership of foreign corporations and partnerships, Forms 8621 (PFICs, default method) and FBARs.

Client was a dual citizen of Canada and the United States with ownership and control (through “related parties” indirect ownership rules) of U.S. and Canadian corporations.  2011 OVDI voluntary disclosure was required for various items, including FBARs, Forms 8891 (RRSPs) and Forms 5471 (Ownership of a Foreign Corporation).  The case involved various corporate tax issues, including extensive US-Canada GAAP compliance.

Sherayzen Law Office guided a U.S. permanent resident through OVDI amnesty program.  The client had extensive PFIC (Form 8621) issues, requiring preparation of amended tax returns using the OVDI Mark-to-Market PFIC method.  Post-OVDI tax planning.

A U.S. permanent resident (a Canadian citizen) inherited partial ownership of a factory in Eastern Europe as well as a large parcel of land. We guided our client through a voluntary disclosure process, amended tax returns going back six years with Forms 8891, and filed delinquent FBARs.

A U.S. permanent resident (a citizen of India) need to go though a modified voluntary disclosure process as well as filing of delinquent FBARs on multiple foreign bank accounts of different nature, including PFICs.

A married couple, a U.S. citizen and a U.K. citizen (both spouses are permanent residents of Australia), needed to go through a traditional voluntary disclosure process (completed after 2009 OVDP closed but before 2011 OVDI commenced) and file delinquent FBARs, disclosing rental income from Australia as well as Australian retirement accounts.

Representative Audit Cases

A corporation was subject to an IRS audit with respect to unfiled employment and income tax returns as well as unpaid employment and income taxes. At the outset, the business and its owner were not represented; the IRS expanded its review to five years, subjecting the business to extreme deadlines with the ultimate intention to dissolve the corporation and criminally charge its owner and officers. Sherayzen Law Office successfully represented the business and its owner, met all of the IRS deadlines, and prepared and filed all Forms 940/941 and 1120. During the final negotiation process, the corporation was preserved, the filing of criminal charges was avoided, the penalties were reduced and the IRS agreed to an installment payment plan.

A Minnesota corporation subject to Minnesota Unemployment Insurance audit on the classification of employees. Initially the client was not properly represented during the initial inquiry process and MUI assessed high taxes and penalties. Sherayzen Law Office requested and successfully conducted the audit, established the classification of more than ninety percent of employees as independent contractors and reduced client’s liability by over 90%.

Representative Foreign Gifts and Inheritance Cases

Client inherited extensive real estate properties in Eastern Europe, partially through a restitution program; complex Form 3520 tax planning was conducted by Sherayzen Law Office in addition to preparation of Form 3520.

Client inherited various rural land parcels, rental properties and cash in India.  A voluntary disclosure was required for various items, including FBARs and Form 3520; reasonable cause was established to the IRS satisfaction.

Client inherited foreign bank accounts in France. Sherayzen Law Office resolved complex voluntary disclosure issues with respect to Form 3520 and FBARs.

Representative International Business and Tax Planning Cases

A Nevada corporation with substantial overseas gold bullion assets and a Nevada limited partnership owned by the same owners. Sherayzen Law Office attorneys were able to identify various tax return errors that resulted in gross over-payment of tax by the corporation and the owners. After the implementation of a comprehensive tax plan, the overall tax liability was reduced by more than 70% in the first year and further went down by about 15% in the second year.

Expatriate, a manager in a multinational logistics company with extensive presence in China, needed proper analysis of foreign tax credit and foreign earned income exclusion options. The case involved preparation of late federal and state tax returns.

Sherayzen Law Office helped a U.S. permanent resident to plan her international tax strategies in conjunction with local counsel. Then, we guided our client through a modified voluntary disclosure process, amended tax returns (including changing the tax status), and brought our client into full compliance with U.S. and foreign tax laws. The result was a net tax saving of over fifty percent.

A growing high-tech Minnesota corporation with about a dozen employees needed a business tax plan for expanding its operations into South Korea and hiring two local engineers. Sherayzen Law Office created a comprehensive expansion plan.

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