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952-500-8159
The substantial presence test is one of the most important legal tests in the Internal Revenue Code (IRC), because it determines whether a person is a US tax resident solely by virtue of his physical presence in the United States. Additionally, this Test is essential to the determination of whether a person is a “US […]
As was the case in the year 2023, I expect that Streamlined Domestic Offshore Procedures will continue to be the flagship offshore voluntary disclosure option in 2024 for US taxpayers who reside in the United States. This is why noncompliant US taxpayers should understand well the main advantages and disadvantages of participating in the 2024 Streamlined Domestic […]
On December 4, 2023, Banque Pictet et Cie SA (“Banque Pictet” – a Swiss private bank) entered into a deferred prosecution agreement with the US government. In this article, I will discuss Banque Pictet Deferred Prosecution Agreement and explain its importance. Banque Pictet Deferred Prosecution Agreement: Facts Leading Up to the Agreement The Pictet Group was […]
An increasing number of submissions under the Streamlined Domestic Offshore Procedures (SDOP) has been subject to an IRS audit; this trend will undoubtedly continue in 2024. In this article, I will explain what an 2024 SDOP Audit is and what a taxpayer should expect during the Audit. 2024 SDOP Audit: Background Information on Streamlined Domestic Offshore Procedures Streamlined Domestic […]
Since 2014, Streamlined Domestic Offshore Procedures (“SDOP”) has probably been the most popular offshore voluntary disclosure option, and I predict that it will remain so in the year 2024. In this article, I would like to explore main four 2024 SDOP advantages which US taxpayers should take into account while considering an offshore voluntary disclosure this year. 2024 […]
A prison term of up to 10 years
Criminal penalties of up to $500,000
or both
Eugene Sherayzen, Esq.
International Tax Attorney
Mr. Sherayzen is the best International Tax Lawyer and Consultant in this part of the country. After extensive research and after talking with a number of companies, including the top big-name consulting companies – I chose Mr. Sherayzen. The difference between Mr. Sherayzen and the rest of the companies are that, while the rest of the companies treat all similar issues in a very generic manner – Mr. Sherayzen approaches each case based on the particular situation and the need of the individual issue at hand. He knows and proves very well that, one size does not fit all. Mr. Sherayzen is very thorough and meticulous in the delivery of his work. He is a subject-matter-expert. Read More
We first came to know about FBAR around end of 2012 and found out that we had some accounts in our home country that should have been reported. Unfortunately, we did not have any knowledge of these accounts and they were opened by our parents when we were minors. It was a complicated and unpleasant situation, exacerbated by a myriad of conflicting information online. Read more…
Maitre Eugene Sherayzen , merci de votre travail excellent et de votre expertise concernant
When we unexpectedly received a distribution from a foreign trust that we had been unaware of, we were suddenly confronted with the convoluted tax rules governing foreign trusts. At first, we sought the help of a regular tax preparer, who was a former IRS employee, but after some time it became clear that he was in way over his head. After a lot of searching, we found Eugene Sherayzen and immediately realized we were in good and knowledgeable hands. Eugene is an expert in this incredibly complex area Read More
I discovered Eugene Sherayzen somewhat accidentally, when I sought his services to help me with a comparatively minor foreign gift reporting form. In the process, he uncovered and then straightened out an extremely messy financial situation created by less than ethical european bankers at the death of my father. The process took several years, involved hundreds of PFIC calculations, and lead to one of the thickest set of tax returns in recent memory… Eugene’s hard work and clear thinking brought it all to a successful conclusion and avoided a potentially ruinous outcome. Through it all, I appreciated Eugene’s integrity, his kindness and sense of humor. He has earned my highest recommendation.
The tax attorney services provided by Mr. Eugene Sherayzen were excellent. Years of paying too little attention to the complicated tax laws regarding foreign accounts, funds and companies lead to a complex situation. Mr. Sherayzen quickly understood the issues and found efficient solutions. I highly recommend Mr. Sherayzen and his law firm.
Mr. Sherayzen assisted us in resolving some tax issues related to foreign accounts. We are completely satisfied with the services he provided and would highly recommend him to anyone needing help in this area. Mr. Sherayzen is very knowledgeable and handled our case in a timely and professional manner. He is also a very nice person, who we believe genuinely cares about helping his clients.
The tax laws on foreign accounts are extraordinarily complex, particularly with regard to mutual funds. My wife and I have been extraordinarily impressed by the expertise and professionalism of Mr. Sherayzen. He found the very best way of approaching our own specific situation and handled everything in an extremely precise, thorough way. His totally above-board, scrupulously honest way… Read more…
Mr. Sherayzen is a subject-matter-expert who is very thorough in gathering complete information, and based on that, provides options and next steps related recommendations. Mr. Sherayzen is very intelligent and is analytical and rational in addressing the issue at hand. He exercises discipline, structure, and rigorous determination in his thinking. At the same time he has exhibited remarkable rational skills … Read more
My wife and I engaged the services of Eugene Sherayzen in 2009, feeling very apprehensive as we were by no means familiar with legal processes. He very quickly made us at ease with his friendly manner and also added to that ease with his professional expertise and obvious knowledge of the legal situation relative to our case. He scheduled our meetings to not only cover the steps necessary, but also… Read more
The tax attorney services provided by Mr. Eugene Sherayzen were excellent. Years of paying too little attention to the complicated tax laws regarding foreign accounts, funds and companies lead to a complex situation. The legal advice and service Mr. Eugene Sherayzen provided to me was absolutely superb. Mr. Sherayzen is comprehensive in his background research, attentive to detail, diligent, and creative. Read more…
I faced to an international tax issue in 2014. The issue was very complicated because the issue included several aspects (such as streamlined disclosure, capital gain tax, Form 8938, FBAR, and state tax) in same time. I tried to contact local CPAs, but they even could not understand what is going on (absolutely they also could not provide any solution at all). I was very frustrated and tried to find an expert on international tax issue. Fortunately, I found Attorney Sherayzen through internet. Once I contacted to Attorney Sherayzen, I did not have to pay attention to the tax issue anymore. Read more…
We were very fortunate to have found such a Tax Attorney, Eugene Sherayzen Esq. Mr. Sherayzen was very personable and made us feel he was truly concerned about our situation and would work with us to correct the errors of the past. Meetings were set up to gather detailed information to fully understand what needed to be corrected and/or amended. We were guided with what was required by us and Mr.Sherayzen was always available to address our questions and/or concerns. Read more
It was early 2012, and a few years after opening an offshore GoldMoney account, that I stumbled upon FBAR and US offshore account reporting requirements. I needed to back-file, and even figure out how to file! Information on how to comply was so scarce, and the fines so high for mistakes that it was a stressful time to say the least! … When I found Eugene Sherayzen via Google, it was already late on a Friday night. I expected to leave a voicemail, suffer through the weekend, and pick things up on the following Monday. He called me right back and from there began a very smooth experience working with a highly competent individual. Read More
Eugene could not save me from months of sleepless nights and stomach-churning anxiety, but his efficiency, meticulous attention to detail, and profound knowledge of the intricacies of the most byzantine of American tax laws saved me and my meagre fortune from ruin. Since then, I have relied on Eugene to prepare my taxes every year. My stomach is much better, and I get plenty of sleep. Eugene is everything you want in a lawyer. He is knowledgeable, thorough, and expeditious, and he doesn’t charge you an arm and a leg. That he is also a nice guy with a sense of humour is icing on the cake. I can enthusiastically recommend him! Read More
Thousands of FBARs, FATCA Forms 8938, Foreign Business and Trust Forms (3520, 3520-A, 5471, 8865, 926, etc.) Filed
Hundreds of Offshore Voluntary Disclosure Cases Successfully Completed
Millions of Dollars Saved in Potential IRS Civil Penalties and Tax Return Liabilities
Criminal Prosecution Successfully Averted
Foreign Account Tax Compliance Act, Form 8938, FATCA Lawyers, International Tax Lawyers
Report of Foreign Bank and Financial Accounts, FinCEN Form 114, TD F 90-22.1, FBAR Penalties, FBAR Lawyers
IRS Offshore Voluntary Disclosure Program, OVDP, International Tax Lawyers
IRS Streamlined Domestic Offshore Procedures, SDOP lawyers, International Tax Lawyers
FBAR Audit, Business IRS Audit, International Tax Return IRS Audit, Material Advisor IRS Audit, International Tax Lawyers
Reporting Foreign Inheritance, Reporting Foreign Gifts, Form 3520, International Estate Planning, International Tax Lawyers
FinCEN Form 114 Indian Financial Accounts Obligations | FBAR Attorney
/in FBAR Lawyers, Legal Notes /by ManagerFinCEN Form 114, the Report of Foreign Bank and Financial Accounts, commonly known as “FBAR”, is one of the most important requirements that Indian Americans face as part of their US tax compliance concerning their Indian Financial Accounts. This articles provides an overview of the Indian American’s FBAR compliance requirements with the particular focus on […]
Orlando Foreign Trust Attorney | International Tax Lawyers Florida
/in foreign trust lawyer, Legal Notes /by ManagerIf you live in Orlando, Florida, and you are an owner or a beneficiary of a foreign trust, you need to secure the help of a Orlando Foreign Trust Attorney to properly comply with US international tax laws. You should consider retaining Sherayzen Law Office as your Orlando Foreign Trust Attorney. Sherayzen Law Office is […]
Miami Foreign Trust Attorney | International Tax Lawyers Florida
/in foreign trust lawyer, Legal Notes /by ManagerIf you live in Miami, Florida, and you are an owner or a beneficiary of a foreign trust, you need to secure the help of a Miami Foreign Trust Attorney to properly comply with US international tax laws. You should consider retaining Sherayzen Law Office as your Miami Foreign Trust Attorney. Sherayzen Law Office is […]
Athens FBAR Attorney | International Tax Lawyer Georgia
/in FBAR Lawyers, Legal Notes /by ManagerIf you reside in Athens, Georgia and have unreported foreign bank and financial accounts, you may be looking for a Athens FBAR Attorney. Sherayzen Law Office, Ltd. is a leader in FBAR compliance, including offshore voluntary disclosures concerning delinquent FBARs, and you should consider us in your search. Let’s understand why this is the case. Athens FBAR Attorney: International […]
Fourth Quarter 2024 IRS Interest Rates on Overpayment & Underpayment of Tax
/in irs lawyer minneapolis, Legal Notes /by ManagerOn August 21, 2024, the IRS announced that the Fourth Quarter 2024 IRS interest rates on overpayment and underpayment of tax will remain the same as in the Third Quarter of 2024. This means that, the Fourth Quarter 2024 IRS interest rates will be as follows: eight (8) percent for overpayments (seven (7) percent in the case of a corporation); eight (8) percent for underpayments; […]