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.

Expatriate, a manager in a multinational logistics company with extensive present 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.

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 married couple, a U.S. citizen and a U.K. citizen (both spouses are permanent residents of Australia), needed to go through a voluntary disclosure process and file delinquent FBARs, disclosing rental income from Australia as well as Australian retirement accounts.

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.

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.

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 PFIC method.  Post-OVDI tax planning.

Client is 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.  A voluntary disclosure was required for various items, including FBARs, PFIC, Forms 8891 and Forms 5471.  The case involved various corporate tax issues, including GAAP compliance.

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.

Complex corporate and personal tax planning provided for a client with substantial overseas gold bullion assets.  A modified voluntary disclosure was conducted with establishment of reasonable cause.  The case also involved complex post-disclosure  capital tax planning.

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