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This is a case which I know very well by heart because this case took four years to complete. It involved a very large number of companies and I’m very proud of that case because there were only two possibilities there. Either my client will pay millions in penalties or he will pay zero; he […]
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 […]