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FBAR tax lawyer and attorney explains the FBAR financial interest definition. FBAR tax lawyer discusses six different categories of FBAR financial interest.
The closure of the IRS flagship 2014 Offshore Voluntary Disclosure Program (“OVDP”) in September of 2018 posed a critical issue of the 2019 offshore voluntary disclosure options available to US taxpayers. This is precisely the issue that I would like to explore today – the 2019 offshore voluntary disclosure options available to US taxpayers who […]
An analysis of the fiscal year 2018 DOJ criminal case statistics reveals certain interesting patterns about federal criminal tax prosecution in that year. Let’s explore in more detail these patterns. 2018 DOJ Criminal Case Statistics: Typical Tax Criminal The analysis of the FY 2018 DOJ criminal case statistics reveals an interesting fact – a typical […]
Mr. Eugene Sherayzen, the founder and owner of Sherayzen Law Office, Ltd., is a premier Minneapolis Minnesota Voluntary Disclosure Lawyer. Why is this the case? Let’s explore the top five reasons for it. Premier Minneapolis Minnesota Voluntary Disclosure Lawyer: Experience Mr. Sherayzen started practicing law at the end of 2005. In other words, he has […]
Streamlined Foreign Offshore Procedures (“SFOP”) is currently the preferred offshore voluntary disclosure option for US taxpayers who reside overseas, recently came to the United States or recently left the United States. Hence, the issue of SFOP eligibility (i.e. the ability of a taxpayer to participate in this program) is very important for these taxpayers. Today, […]
A prison term of up to 10 years
Criminal penalties of up to $500,000
or both
Eugene Sherayzen, Esq.
International Tax Attorney
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
IRS Acquires Phone-Hacking Software | IRS Lawyer News
/in IRS Lawyers, Legal Notes /by ManagerIt seems that the IRS audit powers are increasing more and more at the expense of taxpayers’ privacy rights. In June of 2019, the IRS posted a procurement notice on its website to award a contract to a company Cellebrite, an Israeli company that specializes in smartphone decryption software and equipment. In other words, the […]
Minnesota Sales Tax Responsible Person Legal Standard | Audit Tax Lawyer
/in Legal Notes, minneapolis tax lawyer /by ManagerIn this article, I would like to discuss the legal definition of Responsible Person under Minn. Stat. § 270C.56 – I will refer to this term as Minnesota sales tax responsible person legal standard. Minnesota Sales Tax Responsible Person: Background Information Minnesota imposes a sales tax “on the gross receipts from retail sales.” Minn. Stat. […]
2019 Zurich Trip Completed | Zurich US International Tax Lawyer & Attorney
/in International Tax Attorney, Legal Notes /by ManagerIn July of 2019, Mr. Eugene Sherayzen, an international tax attorney and owner of Sherayzen Law Office, Ltd., completed his business trip to Zurich, Switzerland. Let’s discuss in more detail this 2019 Zurich Trip, its goals and accomplishments. 2019 Zurich Trip: Goals Mr. Sherayzen outlined the firm’s goals for the Zurich trip during the Sherayzen […]
2019 Karlovy Vary Trip Completed | US International Tax Lawyer & Attorney
/in International Tax Attorney, Legal Notes /by ManagerMr. Eugene Sherayzen, an international tax attorney and owner of Sherayzen Law Office, Ltd., completed his trip to Karlovy Vary, Czech Republic, on July 10, 2019. Let’s discuss in more detail this brief 2019 Karlovy Vary trip, its motivations and results. 2019 Karlovy Vary Trip: Reasons for this Excursion There were several reasons why Mr. […]
Legal Entity Identifiers: Introduction to LEI | International Tax Lawyer & Attorney
/in business tax lawyers minneapolis, Legal Notes /by ManagerThe Legal Entity Identifiers (“LEI”) is a method to identify legal entities that engage in financial transactions. Let’s discuss LEI in more detail. LEI: Background Information The establishment of LEI was driven by the recognition by regulators around the world that there is a complete lack of transparency with respect to identifying parties to international […]