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International Tax News & Analysis:

§318 Re-attribution: General Rule | International Tax Lawyers Miami

This article continues a series of articles on the Internal Revenue Code (“IRC”) §318 constructive ownership rules. Today, I would like to focus on the §318 re-attribution rule. In this article, I will explain the general §318 re-attribution rule and mention the exceptions. I will discuss the exceptions in more detail in future articles. §318 […]

Liechtenstein Stiftung: US Tax Classification | Foreign Trust Tax Lawyer

This article continues a series of articles on foreign trust classification with respect to various foreign entities. Today’s topic is the US tax treatment of a Liechtenstein Stiftung. Liechtenstein Stiftung: Formation A Liechtenstein Stiftung, or Foundation, is a legal entity under Liechtenstein law. It may be formed by filing a foundation charter or by will […]

Liechtenstein Anstalt: US Tax Treatment | Foreign Trust Lawyer & Attorney

February 8, 2020/in foreign trust lawyer, Legal Notes /by Manager

Over the years, the IRS has made a number of rulings with respect to whether certain foreign entities should be considered trusts for US tax purposes. In this article, I would like to discuss the US tax classification of Liechtenstein Anstalt based on the 2009 IRS Chief Counsel Advice Memorandum, AM 2009-012. Liechtenstein Anstalt: Creation […]

New Form 1040-SR for Seniors | US Tax Lawyers & Attorneys

February 7, 2020/in Legal Notes, tax lawyers st paul /by Manager

For the very first time, the IRS has created a new tax form called Form “1040-SR”. “SR” here standards for “seniors”. The idea is that the new form will be used by senior taxpayers. Let’s discuss Form 1040-SR in more detail. Form 1040-SR: Reasons for Its Creation The reason for the creation of Form 1040-SR […]

Form 114 Trust Filers | FBAR Tax Lawyer & Attorney Nevada Las Vegas

February 4, 2020/in FBAR Lawyers, Legal Notes /by Manager

FinCEN Form 114 trust filers constitute a highly problematic category of FBAR filers. Form 114 trust filers are problematic not so much because the FBAR requirement itself is unclear, but, rather, because the trustees do not realize that this requirement applies to them. In this article, I would like to educate potential Form 114 trust […]

2020 Offshore Voluntary Disclosure Options | US International Tax Lawyers

January 13, 2020/in Lead Article, offshore voluntary disclosure lawyers Minneapolis /by Manager

As the new year 2020 begins, it is important for US taxpayers with undisclosed foreign assets to consider their 2020 offshore voluntary disclosure options. Unlike last year, there have not been any drastic changes to the voluntary disclosure options since 2019. In this article, I would like to generally explore the 2020 offshore voluntary disclosure […]

FBAR Financial Interest Definition | FBAR International Tax Lawyer & Attorney | FinCEN Form 114

March 30, 2019/in FBAR, Lead Article /by Manager

FBAR tax lawyer and attorney explains the FBAR financial interest definition. FBAR tax lawyer discusses six different categories of FBAR financial interest.

2020 SDOP Eligibility Requirements | SDOP Tax Lawyer & Attorney

January 20, 2020/in Legal Notes, offshore voluntary disclosure lawyers Minneapolis, Streamlined Domestic Offshore Procedures /by Manager

In a recent article, I mentioned that Streamlined Domestic Offshore Procedures (“SDOP”) will continue to be the most important voluntary disclosure option in 2020 for US taxpayers who reside in the United States. However, not all taxpayers will qualify to participate in the 2020 SDOP. In this article, I will discuss the main 2020 SDOP […]

2020 Streamlined Domestic Offshore Procedures: Pros and Cons

January 15, 2020/in Legal Notes, offshore voluntary disclosure lawyers Minneapolis, Streamlined Domestic Offshore Procedures /by Manager

Noncompliant US taxpayers with undisclosed foreign assets and foreign income should consider their voluntary disclosure options in this new year 2020. Similarly to 2019, I expect that this year Streamlined Domestic Offshore Procedures will continue to be the flagship voluntary disclosure option for such taxpayers who reside in the United States. In order for the […]

2020 Offshore Voluntary Disclosure Options | US International Tax Lawyers

January 13, 2020/in Lead Article, offshore voluntary disclosure lawyers Minneapolis /by Manager

Potentially, a person who willfully fails to file a Report of Foreign Bank and Financial Accounts (FBAR) or files a false FBAR may be subject to:

A prison term of up to 10 years
Criminal penalties of up to $500,000
or both

FBAR, FATCA, Streamlined Foreign Offshore Procedures, Streamlined Domestic Offshore Procedures, OVDP, Foreign Inheritance, Foreign Gifts, Ownership of Foreign Business, Gold Bullion Accounts, PFICs, FATCA Form 8938, IRS Appeals, Form 5471, Form 8865, Form 8621, Form 8858, Foreign Trust Owners (Form 3520-A), Foreign Trust Beneficiary (Form 3520), International Tax Compliance, FBAR, FATCA, International Tax Planning, Subpart F Rules, IRS Form 8938, International Tax Lawyers, Form 5471 (Ownership of a Foreign Corporation)

Eugene Sherayzen, Esq.
International Tax Attorney

Testimonials Of Some Of The People We Have Helped:

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

MKH

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…

Goyal FamilyMinnesota

Maitre Eugene Sherayzen , merci de votre travail excellent et de votre expertise concernant les issues FBAR et “voluntary disclosure ” . Being a Swiss citizen living in the USA , Maitre Sherayzen helped me with my situation in a way that was outstanding. Beside his professional brilliance he can also read documents in French and other languages and understands the cultural differences between countries . Maitre Sherayzen you are a gem! I will recommend his law firm to anyone who needs a fantastic attorney in international tax law.

Marie-Jeanne Delevaux-HargittMinneapolis

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

Dennis and Stephanie, Minnesota

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.

René Coppieters

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.

Kurt

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.

Gerrard MacintoshPh.D.

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…

Karl Fredrickson

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

Muhammed H.

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

Stanley and Diane Coombes

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…

Dmitriy Fooks

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…

Client Chose to Keep His Name ConfidentialStreamlined Domestic Offshore Procedures

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

P & C Arkansas

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

Ben from Illinois

I have been working with Mr. Sherayzen for several years now and have found him and his staff to be

efficient, professional and effective. As a entrepreneur, I often have to bring people in with expertise

in fields I know nothing about. Mr. Sherayzen is that person Read More

Michael from Carlsbad CA

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

John Dixon

For almost 13 years, our international tax law firm, Sherayzen Law Office, Ltd., has been working hard, helping our clients save millions of dollars by preventing and reducing the IRS penalties:

Eugene Sherayzen, Esq. International Tax Attorney.

Forms

Thousands of FBARs, FATCA Forms 8938, Foreign Business and Trust Forms (3520, 3520-A, 5471, 8865, 926, etc.) Filed

Disclosures

Hundreds of Offshore Voluntary Disclosure Cases Successfully Completed

Savings

Millions of Dollars Saved in Potential IRS Civil Penalties and Tax Return Liabilities

Protection

Criminal Prosecution Successfully Averted

Eugene Sherayzen, Esq. is a member of the International Business Law & Tax Sections of
The Minnesota State Bar Association

Our Firm’s International Tax Law Expertise:

FATCA

Foreign Account Tax Compliance Act, Form 8938, FATCA Lawyers, International Tax Lawyers

FBAR

Report of Foreign Bank and Financial Accounts, FinCEN Form 114, TD F 90-22.1, FBAR Penalties, FBAR Lawyers

OVDP

IRS Offshore Voluntary Disclosure Program, OVDP, International Tax Lawyers

Streamlined Domestic Offshore Procedures

IRS Streamlined Domestic Offshore Procedures, SDOP lawyers, International Tax Lawyers

IRS Audits & Tax Litigation

FBAR Audit, Business IRS Audit, International Tax Return IRS Audit, Material Advisor IRS Audit, International Tax Lawyers

Foreign Inheritance and Foreign Gifts

Reporting Foreign Inheritance, Reporting Foreign Gifts, Form 3520, International Estate Planning, International Tax Lawyers

Are you a U.S. Tax Resident? If you are, then a whole avalanche of tax reporting requirements will apply to you. International Tax Lawyer & Attorney Eugene Sherayzen, Esq. explains the substantial presence test that will determine if you are a U.S. tax resident:

Welcome To Sherayzen Law Office – International Tax Lawyers Experienced, Efficient and Reliable Tax Law Firm

International Tax News & Analysis:

§318 Re-attribution: General Rule | International Tax Lawyers Miami

Liechtenstein Stiftung: US Tax Classification | Foreign Trust Tax Lawyer

Liechtenstein Anstalt: US Tax Treatment | Foreign Trust Lawyer & Attorney

New Form 1040-SR for Seniors | US Tax Lawyers & Attorneys

Form 114 Trust Filers | FBAR Tax Lawyer & Attorney Nevada Las Vegas

Featured International Tax Law Article:

2020 Offshore Voluntary Disclosure Options | US International Tax Lawyers

FBAR Financial Interest Definition | FBAR International Tax Lawyer & Attorney | FinCEN Form 114

Voluntary Disclosure News:

2020 SDOP Eligibility Requirements | SDOP Tax Lawyer & Attorney

2020 Streamlined Domestic Offshore Procedures: Pros and Cons

2020 Offshore Voluntary Disclosure Options | US International Tax Lawyers

Criminal Penalties & Prosecution For Not Reporting Your Foreign Bank Accounts

Potentially, a person who willfully fails to file a Report of Foreign Bank and Financial Accounts (FBAR) or files a false FBAR may be subject to:

Testimonials Of Some Of The People We Have Helped:

For almost 13 years, our international tax law firm, Sherayzen Law Office, Ltd., has been working hard, helping our clients save millions of dollars by preventing and reducing the IRS penalties:

Forms

Disclosures

Savings

Protection

Eugene Sherayzen, Esq. is a member of the International Business Law & Tax Sections of
The Minnesota State Bar Association

Our Firm’s International Tax Law Expertise:

FATCA

FBAR

OVDP

Streamlined Domestic Offshore Procedures

IRS Audits & Tax Litigation

Foreign Inheritance and Foreign Gifts

Are you a U.S. Tax Resident? If you are, then a whole avalanche of tax reporting requirements will apply to you. International Tax Lawyer & Attorney Eugene Sherayzen, Esq. explains the substantial presence test that will determine if you are a U.S. tax resident:

Call now to schedule a confidential consultation at
952-500-8159

International Tax Law Websites

Categories

Recent Posts

Welcome To Sherayzen Law Office – International Tax Lawyers Experienced, Efficient and Reliable Tax Law Firm

International Tax News & Analysis:

Featured International Tax Law Article:

Voluntary Disclosure News:

Criminal Penalties & Prosecution For Not Reporting Your Foreign Bank Accounts

Potentially, a person who willfully fails to file a Report of Foreign Bank and Financial Accounts (FBAR) or files a false FBAR may be subject to:

Testimonials Of Some Of The People We Have Helped:

For almost 13 years, our international tax law firm, Sherayzen Law Office, Ltd., has been working hard, helping our clients save millions of dollars by preventing and reducing the IRS penalties:

Eugene Sherayzen, Esq. is a member of the International Business Law & Tax Sections of The Minnesota State Bar Association

Our Firm’s International Tax Law Expertise:

Are you a U.S. Tax Resident? If you are, then a whole avalanche of tax reporting requirements will apply to you. International Tax Lawyer & Attorney Eugene Sherayzen, Esq. explains the substantial presence test that will determine if you are a U.S. tax resident:

Call now to schedule a confidential consultation at 952-500-8159

International Tax Law Websites

Categories

Recent Posts

Eugene Sherayzen, Esq. is a member of the International Business Law & Tax Sections of
The Minnesota State Bar Association

Call now to schedule a confidential consultation at
952-500-8159