Hello and welcome to Sherayzen Video Blog. My name is Eugene Sherayzen and I’m an international tax attorney and owner of Sherayzen Law Office, Ltd.
Today, I’m in Montevideo, Uruguay and I’ve come here because I have a number of meetings with Uruguayan attorneys here. This is a wonderful nation and a wonderful city. It’s very small-scale European compared to Buenos Aires, for example which feels more like a large European city.
I’d like to begin this series of Montevideo with a discussion of what place Uruguay has in the international tax system. Uruguay is very well known for its adherence to a territorial system of taxation, which is very different from that of the United States.
People here on most of their income, only pay taxes on certain worldwide passive income for local residents, unless you’re a newcomer. In this case the Uruguayan government gives you 11 years of tax-free dividends, interest and other types of income that come from outside of Uruguay, if you become a Uruguayan tax resident with certain exceptions for passive income but overall Uruguay is a territorial system of taxation and as such, offers tremendous opportunities for US taxpayers to properly utilize the Uruguayan tax system to minimize their tax burden in the United States including for US taxpayers who wish to surrender their US tax residency and US taxpayers who wish to give up their US citizenship.
In addition to that, the territorial system of taxation with respect to Uruguayan corporations, is also a very valuable asset for US international tax planning. Overall Uruguay, while it’s a small country, has considerable influence – enough to draw the attention of the European Union which has been pressuring Uruguay to change its system and in fact, the Uruguayan government has made a commitment to modify its territorial system of taxation when it comes to IP (intellectual property) income. The details of this commitment are not yet known. What the final law will look like, is not yet known and so as of today, Uruguay continues to be a very attractive place in terms of US international tax planning.
In the next blog, I will continue talking about Uruguay and US international tax reporting requirements.
Thank you for watching, until the next time.
http://sherayzenlaw.com/wp-content/uploads/2018/01/sherlawltd_logo.png00adminhttp://sherayzenlaw.com/wp-content/uploads/2018/01/sherlawltd_logo.pngadmin2024-11-05 15:58:292024-11-05 16:23:26Uruguay & International Tax Planning | Montevideo US International Tax Lawyer & Attorney
Hello and welcome to Sherayzen Video Blog. My name is Eugene Sherayzen and I’m an international tax attorney and owner of Sherayzen Law Office, Ltd.
Today, I’m continuing a series of blogs from San Antonio, Texas. This series of blogs is pretty much devoted to IRS audits, specifically IRS audits of foreign assets and foreign income.
In this blog, I would like to discuss an issue that should concern you in every IRS audit. How should your defense be structured? Of course, I’m not going to be talking about the details of that strategy; that’s impossible because every strategy has to be based on facts of that particular case. It has to be adapted to the particulars of each case; I’m just talking about what the general plan would be and how you choose your strategy.
There are three most important points when choosing a plan of defense in an IRS audit:
The first one, I’ve already mentioned, whatever the plan is, it has to be based on the facts of the case – very important. It should not be an abstract plan of defense; it should be one that is based specifically on your facts and circumstances.
The second point is that it should be based on the documentation that you have or may be able to get, because ultimately, in the IRS audit, the party that can produce documents to prove its point is the one that will prevail on that point unless the evidence is unconvincing or fraudulant of course. I want to take this opportunity to say that you should never, never ever submit fraudulant documentation to the IRS. Having said that, it doesn’t mean that you cannot produce documentation, that is you can get testimony from a third party or parties about an event that happened. For example, if there was a repair or major repair done to a building that you owned, then you can go to the contractor and get a statement from the contractor that the major repair was done, this is how much was paid to me for doing this and this and this work. Of course, if the builder has the original invoices, even better.
Point number three is that whatever the strategy is that you choose must be logical and should be presented in the form of a story about what had happened. Basically, if your story does not make sense, it’s not a good strategy. Strategy must be logical and based on the facts of the case – a logical sequence of events – very important.
If you’re being audited by the IRS, and you would like to secure professional help with respect to your IRS audit, you can call me at (952) 500-8159 or you can email me at [email protected]
Thank you for watching, until the next time.
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Hello and welcome to Sherayzen Video Blog. My name is Eugene Sherayzen and I’m an international tax attorney and owner of Sherayzen Law Office, Ltd.
Today, I’m continuing a series of blogs from San Antonio, Texas and this series of blogs is devoted to IRS audits, how they happen, when they happen and what way is the best way in dealing with them.
In the previous blog, I discussed how one should behave with respect to IRS agents. In this blog I’d like to discuss a slightly different issue and step away a little bit directly from litigation and talk about San Antonio’s specific issues. In particular, I want to talk about FBAR compliance for San Antonians: FBAR, the report of foreign bank and financial accounts is one of the most important information returns that one has to file with respect to his foreign bank and financial accounts, specifically with respect to his financial interest in or signatory authority over foreign bank and financial accounts.
In this case, we’re talking about foreign accounts which are located outside of the United States of course. When we are talking about FBAR compliance, with respect to San Antonians, you have to understand what countries are most likely to be involved in FBAR compliance. What I’m talking about is specifically with respect to San Antonians. From my experience here, most of the San Antonians, who have to file FBARs, have assets in Mexico, Spain and/or Germany. In reality, you sometimes get people from all over the world; there are people from Sri Lanka, for example. There are also people from England, people from Italy, Colombia and so basically while Spain, Germany and Mexico are the major countries involved in FBAR compliance, these are not the only countries. It is very important to be in compliance with your FBAR requirements; I cannot stress this enough. We’re talking about humongous penalties in case of FBAR noncompliance; penalties that may extend to actual jail time depending on the circumstances of the (your) case.
If you would like to learn more about FBAR compliance and you are a resident of San Antonio, call me at (952) 500-8159 or email me at [email protected]
Thank you for watching, until the next time.
http://sherayzenlaw.com/wp-content/uploads/2018/01/sherlawltd_logo.png00adminhttp://sherayzenlaw.com/wp-content/uploads/2018/01/sherlawltd_logo.pngadmin2024-09-05 22:27:072024-09-06 17:04:26FBAR Compliance in San Antonio | FBAR International Tax Lawyer San Antonio Texas
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Uruguay & International Tax Planning | Montevideo US International Tax Lawyer & Attorney
/in International tax attorney & lawyer Video /by adminHello and welcome to Sherayzen Video Blog. My name is Eugene Sherayzen and I’m an international tax attorney and owner of Sherayzen Law Office, Ltd.
Today, I’m in Montevideo, Uruguay and I’ve come here because I have a number of meetings with Uruguayan attorneys here. This is a wonderful nation and a wonderful city. It’s very small-scale European compared to Buenos Aires, for example which feels more like a large European city.
I’d like to begin this series of Montevideo with a discussion of what place Uruguay has in the international tax system. Uruguay is very well known for its adherence to a territorial system of taxation, which is very different from that of the United States.
People here on most of their income, only pay taxes on certain worldwide passive income for local residents, unless you’re a newcomer. In this case the Uruguayan government gives you 11 years of tax-free dividends, interest and other types of income that come from outside of Uruguay, if you become a Uruguayan tax resident with certain exceptions for passive income but overall Uruguay is a territorial system of taxation and as such, offers tremendous opportunities for US taxpayers to properly utilize the Uruguayan tax system to minimize their tax burden in the United States including for US taxpayers who wish to surrender their US tax residency and US taxpayers who wish to give up their US citizenship.
In addition to that, the territorial system of taxation with respect to Uruguayan corporations, is also a very valuable asset for US international tax planning. Overall Uruguay, while it’s a small country, has considerable influence – enough to draw the attention of the European Union which has been pressuring Uruguay to change its system and in fact, the Uruguayan government has made a commitment to modify its territorial system of taxation when it comes to IP (intellectual property) income. The details of this commitment are not yet known. What the final law will look like, is not yet known and so as of today, Uruguay continues to be a very attractive place in terms of US international tax planning.
In the next blog, I will continue talking about Uruguay and US international tax reporting requirements.
Thank you for watching, until the next time.
Building IRS Audit Defense Strategy | International Tax Lawyer & Attorney San Antonio
/in International tax attorney & lawyer Video /by adminHello and welcome to Sherayzen Video Blog. My name is Eugene Sherayzen and I’m an international tax attorney and owner of Sherayzen Law Office, Ltd.
Today, I’m continuing a series of blogs from San Antonio, Texas. This series of blogs is pretty much devoted to IRS audits, specifically IRS audits of foreign assets and foreign income.
In this blog, I would like to discuss an issue that should concern you in every IRS audit. How should your defense be structured? Of course, I’m not going to be talking about the details of that strategy; that’s impossible because every strategy has to be based on facts of that particular case. It has to be adapted to the particulars of each case; I’m just talking about what the general plan would be and how you choose your strategy.
There are three most important points when choosing a plan of defense in an IRS audit:
If you’re being audited by the IRS, and you would like to secure professional help with respect to your IRS audit, you can call me at (952) 500-8159 or you can email me at [email protected]
Thank you for watching, until the next time.
FBAR Compliance in San Antonio | FBAR International Tax Lawyer San Antonio Texas
/in International tax attorney & lawyer Video /by adminHello and welcome to Sherayzen Video Blog. My name is Eugene Sherayzen and I’m an international tax attorney and owner of Sherayzen Law Office, Ltd.
Today, I’m continuing a series of blogs from San Antonio, Texas and this series of blogs is devoted to IRS audits, how they happen, when they happen and what way is the best way in dealing with them.
In the previous blog, I discussed how one should behave with respect to IRS agents. In this blog I’d like to discuss a slightly different issue and step away a little bit directly from litigation and talk about San Antonio’s specific issues. In particular, I want to talk about FBAR compliance for San Antonians: FBAR, the report of foreign bank and financial accounts is one of the most important information returns that one has to file with respect to his foreign bank and financial accounts, specifically with respect to his financial interest in or signatory authority over foreign bank and financial accounts.
In this case, we’re talking about foreign accounts which are located outside of the United States of course. When we are talking about FBAR compliance, with respect to San Antonians, you have to understand what countries are most likely to be involved in FBAR compliance. What I’m talking about is specifically with respect to San Antonians. From my experience here, most of the San Antonians, who have to file FBARs, have assets in Mexico, Spain and/or Germany. In reality, you sometimes get people from all over the world; there are people from Sri Lanka, for example. There are also people from England, people from Italy, Colombia and so basically while Spain, Germany and Mexico are the major countries involved in FBAR compliance, these are not the only countries. It is very important to be in compliance with your FBAR requirements; I cannot stress this enough. We’re talking about humongous penalties in case of FBAR noncompliance; penalties that may extend to actual jail time depending on the circumstances of the (your) case.
If you would like to learn more about FBAR compliance and you are a resident of San Antonio, call me at (952) 500-8159 or email me at [email protected]
Thank you for watching, until the next time.