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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 […]
On August 27, 2019, the US Department of Justice (“DOJ”) announced that a federal grand jury returned a superseding indictment charging Mr. Brian Booker, a former resident of Fort Lauderdale, Florida, whose business specialized in international trade, with failing to file Reports of Foreign Bank and Financial Accounts (“FBARs”) and filing false documents with the […]
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 […]
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
The Norman Case: Willful FBAR Penalty Upheld | FBAR Lawyers Miami
/in FBAR audit tax attorney, Legal Notes /by ManagerOn November 8, 2019, the Federal Circuit Court of Appeals (the “Court”) upheld the decision of the Court of Federal Claims to uphold the IRS assessment of a willful FBAR penalty in the amount of $803,530 with respect to Ms. Mindy Norman’s failure to file her 2007 FBAR. The Norman case deserves special attention because […]
New FBAR Filing Verification Submission Process | FBAR Lawyer & Attorney
/in FBAR Lawyers, Legal Notes /by ManagerOn November 19, 2019, the IRS announced changes to the current FBAR filing verification submission process. The change is technical, but not without importance.
November 21 2019 BSU Seminar in Minsk, Belarus | International Tax News
/in International Tax Attorney, Legal Notes /by ManagerOn November 21, 2019, Mr. Eugene Sherayzen, an international tax attorney and founder of Sherayzen Law Office, Ltd., conducted a seminar at the Belarusian State University Law School (the “2019 BSU Seminar”) in Minsk, Belarus. Let’s explore the 2019 BSU Seminar in more detail. 2019 BSU Seminar: Topic and Attendance The topic of the seminar […]
Greek Flat Tax Residency: Draft Bill | International Tax Lawyer News
/in International Tax Attorney, Legal Notes /by ManagerThe new Greek government headed by Prime Minister Kyriakos Mitsotakis wishes to reach 2.8% economic growth next year. Part of the plan to achieve this goal includes a tax reform which introduces a curious new concept of Greek flat tax residency for wealthy foreign investors. Let’s discuss this interesting idea in more detail. Greek Flat […]
Foreign Income Reporting Without Forms W-2 or 1099 | Tax Lawyer
/in international tax lawyer, Legal Notes /by ManagerThere is a surprisingly large number of US taxpayers who believe that reporting foreign income that was not disclosed on a Form W-2 or 1099 is unnecessary. Even if they honestly believe it to be true, this erroneous belief exposes these taxpayers to an elevated risk of imposition of high IRS penalties. In this article, […]