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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
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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
Inbound Transactions Tax Framework | US International Tax Lawyer & Attorney
/in International Tax Attorney, Legal Notes /by ManagerInbound transactions deal with Non-US persons who operate in and/or derive income from the United States. This introductory essay opens a series of articles concerning US taxation of inbound transactions. Today, I will set forth the general inbound transactions tax framework; in future articles, I will explore in more detail each element of this framework. […]
2020 FBAR Criminal Penalties | FBAR International Tax Lawyers
/in FBAR Lawyers, Legal Notes /by Manager2020 FBAR criminal penalties is a potential threat to any US taxpayer who willfully failed to file his FBARs or knowingly filed a false FBAR. In this essay, I would like to review the 2020 FBAR criminal penalties that these noncompliant US taxpayers may have to face. 2020 FBAR Criminal Penalties: Background Information A lot […]
FBAR Voluntary Disclosure | International Tax Lawyer & Attorney
/in Legal Notes, offshore voluntary disclosure lawyers Minneapolis /by ManagerI often receive calls from prospective clients who talk about FBAR voluntary disclosure. They usually have no clear idea of what is meant by this term and what its requirements are. In this article, I will discuss this concept of FBAR Voluntary Disclosure and explain how this concept covers a variety of offshore voluntary disclosure […]
Beware of Flat-Fee Lawyers Doing Streamlined Domestic Offshore Procedures
/in International Tax Attorney, Legal Notes /by ManagerRecently, I received a number of phone calls and emails from people who complained about incorrect filing of their Streamlined Domestic Offshore Procedures (“SDOP”) packages by lawyers who took their cases on a flat-fee basis. In this article, I would like to discuss why a flat fee is generally not well-suited for a proper SDOP […]
October 31 2020 FBAR Deadline | FBAR Tax Lawyer & Attorney
/in FBAR Lawyers, Legal Notes /by ManagerUS taxpayers can still timely file their 2019 FBAR (Report of Foreign Bank and Financial Accounts) by the new October 31 2020 FBAR deadline. This FBAR deadline extension is highly unusual and requires some explanation. October 31 2020 FBAR Deadline: What is FBAR? The Report of Foreign Bank and Financial Accounts (“FBAR”) is officially known […]