Posts

Houston FBAR Attorney | International Tax Lawyer Texas

/in , /by

If you reside in Houston, Texas and have unreported foreign bank and financial accounts, you may be looking for a Houston FBAR Attorney.  Sherayzen Law Office, Ltd. is a leader in FBAR compliance, including offshore voluntary disclosures concerning delinquent FBARs, consider us in your search. Let’s understand why this is the case.

Houston FBAR Attorney: International Tax Lawyer

First of all, it is very important to understand that, by looking for Houston FBAR attorney, in reality, you are searching for an international tax lawyer who specializes in FBAR compliance.

The reason for this conclusion is the fact that FBAR enforcement belongs to a very special field of US tax law – US international tax law. FBAR is an information return concerning foreign assets, which necessarily involves US international tax compliance concerning foreign assets/foreign income. Moreover, ever since the FBAR enforcement was turned over to the IRS in 2001, the term FBAR attorney applies almost exclusively to tax attorneys.

Hence, when you look for an FBAR attorney, you are looking for an international tax attorney with a specialty in FBAR compliance.

Houston FBAR Attorney: Broad Scope of Compliance and Offshore Voluntary Disclosures

When retaining Houston FBAR attorney, consider the fact that such an attorney’s work is not limited only to the preparation and filing of FBARs. Rather, the attorney should be able to deliver a variety of tax services and freely operate with experience and knowledge in all relevant areas of US international tax law, including the various offshore voluntary disclosure options concerning delinquent FBARs.

Moreover, as part of an offshore voluntary disclosure, an FBAR Attorney often needs to amend US tax returns, properly prepare foreign financial statements according to US GAAP, correctly calculate PFICs, and complete an innumerable number of other tasks.

Mr. Sherayzen and his team of motivated experienced tax professionals of Sherayzen Law Office have helped hundreds of US taxpayers worldwide to bring their tax affairs into full compliance with US tax laws. This work included the preparation and filing of offshore voluntary disclosures concerning delinquent FBARs. Sherayzen Law Office offers help with all kinds of offshore voluntary disclosure options, including: SDOP (Streamlined Domestic Offshore Procedures), SFOP (Streamlined Foreign Offshore Procedures), DFSP (Delinquent FBAR Submission Procedures), DIIRSP (Delinquent International Information Return Submission Procedures), IRS VDP (IRS Voluntary Disclosure Practice) and Reasonable Cause disclosures.

Houston FBAR Attorney: Out-Of-State International Tax Lawyer

Whenever you are looking for an attorney who specializes in US international tax law (which is a federal area of law, not a state one), you do not need to limit yourself to lawyers who reside in Houston, Texas. On the contrary, consider international tax attorneys who reside in other states and help Houston residents with their FBAR compliance.

Contact Sherayzen Law Office for Professional FBAR Help

Sherayzen Law Office is an international tax law firm that specializes in US international tax compliance, including FBARs. While our office is in Minneapolis, Minnesota, we help taxpayers who reside throughout the United States, including Houston, Texas.

Thus, if you are looking for a Houston FBAR Attorney, contact Mr. Sherayzen as soon as possible to schedule Your Confidential Consultation!

Houston FBAR Lawyer | OVDP FATCA Tax Attorney

/0 Comments/in , /by

The main thesis of this essay is that the designation of a Houston FBAR Lawyer should be applied based on the geography of services of an FBAR lawyer rather the physical location of a lawyer.

Houston FBAR Lawyer Definition: Legal FBAR Services Provided in Houston, Texas

The old designation where a Houston FBAR Lawyer designation was limited only to lawyers who reside in Houston was incorrect from the very beginning for two reasons.

First, it was based basically on the premise that an out-of-state lawyer cannot effectively provide any legal services to a client who resides in Houston, Texas. Perhaps, to a certain degree, this premise could have been applicable to the time when there were no telephones, emails or other forms of modern communication. However, since the appearance of telephone and Internet-based communications, a modern lawyer can provide services efficiently and effectively at almost any point around the globe as long as he is licensed to do so. Even the face-to-face meetings can now be replaced with video conferences over the Internet (for example, video Skype conferences).

Second, some credence should be given to this old designation in situation where the subject matter is based on local Texas law or required appearance in a Texas court. In these situations, a local attorney indeed appears to have an advantage over an out-of-state attorney (although, even this advantage may be nullified if this is a one-time court appearance or the out-of-state attorney is actually licensed to practice in the State of Texas).

However, a Houston FBAR lawyer deals strictly with just federal subject-matter, because FBAR is a federal law and any US international tax lawyer can practice it irrespective of his physical location as long as this attorney is licensed to practice law in any of the 50 states or District of Columbia. This means that, as long as an international tax lawyer offers his legal FBAR services in Houston, he should be considered a Houston FBAR lawyer even if he resides in Minneapolis.

Houston FBAR Lawyer’s Knowledge of US International Tax Law is the Key Factor

While the physical location of a lawyer is not important in determining whether he is a Houston FBAR lawyer, it is necessary that this lawyer be an international tax lawyer experienced in FBAR issues.

This emphasis on competence in US international tax law is based on the fact that FBAR is just a part of a much bigger area of US international tax law. In fact, the FBAR and international tax law are so completely interrelated this interaction between FBAR and other international tax issues is crucial to determining a taxpayer’s legal position. This is why your Houston FBAR lawyer should have a profound understanding of both FBARs and all other relevant US international tax compliance requirements.

Sherayzen Law Office Should Be Your Houston FBAR Lawyer

Sherayzen Law Office is a highly experienced international tax law firm with profound knowledge of FBARs and all other relevant US international tax compliance requirements. Our team consists of highly-experienced international tax professionals headed by the founder of the firm, attorney Eugene Sherayzen. We have helped hundreds of US taxpayers worldwide with their FBAR issues and we can help you!

This is why, if you are looking for a Houston FBAR lawyer, you should contact Sherayzen Law Office, Ltd. today to schedule Your Confidential Consultation!

Swiss Bank Program Update: Bank Zweiplus and Banca Stato del Cantone Ticino

/0 Comments/in , /by

On August 20, 2015, the US Department of Justice announced another Swiss Bank Program update – Bank Zweiplus AG (Bank Zweiplus) and Banca dello Stato del Cantone Ticino (Banca Stato) have reached resolutions under the department’s Swiss Bank Program.

The Swiss Bank Program, which was announced on August 29, 2013, provides a path for Swiss banks to resolve potential criminal liabilities in the United States. Swiss banks eligible to enter the program were required to advise the department by December 31, 2013, that they had reason to believe that they had committed tax-related criminal offenses in connection with undeclared U.S.-related accounts. Banks already under criminal investigation related to their Swiss-banking activities and all individuals were expressly excluded from the program.

Swiss Bank Program Update: Bank Zweiplus Background and Non-Prosecution Agreement

As part of its Swiss Bank Program Update, the DOJ provided various background information regarding Bank Zweiplus. The Bank was founded in July 2008 as a retail bank based in Zurich. Offices located in Geneva and Basel, Switzerland, were closed in 2008 and 2012, respectively. Since Aug. 1, 2008, Bank Zweiplus maintained and serviced 44 U.S.-related accounts with an aggregate value of approximately $12.1 million.

Bank Zweiplus was aware that U.S. taxpayers have a legal duty to report to the Internal Revenue Service (IRS) their ownership of bank accounts outside the United States and to pay taxes on income earned in such accounts. Nevertheless, in disregard of U.S. laws, the bank provided a variety of traditional Swiss banking services that assisted some U.S. taxpayers in concealing their undeclared accounts. For example, Bank Zweiplus maintained numbered accounts and accounts held in the name of structures which were effectively owned or controlled by U.S. persons, including structures in the British Virgin Islands and the Bahamas.

Bank Zweiplus cooperated with the department during its participation in the Swiss Bank Program and encouraged its U.S. clients to enter the IRS Offshore Voluntary Disclosure Program (nowclosed). Bank Zweiplus will pay a penalty of $1.089 million.

Swiss Bank Program Update: Banca Stato Background and Non-Prosecution Agreement

As part of its Swiss Bank Program Update, the DOJ provided various background information regarding Banca Stato. Banca Stato was established in 1915 and is headquartered in Bellinzona, Switzerland. Banca Stato was aware that U.S. taxpayers had a legal duty to report to the IRS and pay taxes on the basis of all of their income, including income earned in accounts that the U.S. taxpayers maintained at the bank. Despite this, the bank opened and serviced accounts for U.S. clients who the bank knew or had reason to know were not complying with their U.S. income tax obligations.

During the applicable period, Banca Stato maintained and serviced 187 U.S.-related accounts with an aggregate maximum balance of approximately $137 million. Banca Stato will pay a penalty of $3.393 million.

Impact of this Swiss Bank Program Update on US Taxpayers

Starting August 20, 2015, noncompliant U.S. accountholders at Bank Zweiplus and Banca Stato must now pay that 50 percent penalty to the IRS if they wish to enter the IRS Offshore Voluntary Disclosure Program.

Follow this link to the DOJ website for more information on this Swiss Bank Program Update.