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Hello and welcome to Sherayzen Law Office Video Blog. My name is Eugene Sherayzen and I’m an International Tax Attorney and owner of Sherayzen Law Office, Ltd. We’re continuing a series of blogs from the Czech Republic, Prague. Today I would like to talk more about FBAR Penalties. In a recent blog, I described the […]
Before we delve into the subject matter of today’s discussion, I’d like to introduce myself so that you know a little bit about who I am and what it is I do. I know that about half of you already know but the other half does not. As I’ve just said in my crude French […]
The Tax Owner is really a Holder of Economic Interest, not necessarily the Legal owner of the actual entity. Let me clarify that with an example. Let’s say this is a Taxpayer; this is the LLC and he owns 100% of that LLC. The LLC owns 50% of the Limited Partnership. The Taxpayer owns 50% […]
US Owners: I listed out for you what US Owner means. It’s US Citizens, US Tax Residents, meaning Permanent Residents and a person who has satisfied the US Presence Test, Non-residents who declare themselves as Tax Residents for the purposes of filing a joint tax return are also considered to be US Owners. Residents of […]
The question of a Business Entity actually involves a complex analysis and I lay out some of it here; it is a very simplified analysis but basically the very first question that we have to ask is: Is there a Business Entity? I’m going to jump to the point 1b right away. Suppose that ‘Pierre’ […]