Entries by Manager

Reasonable Cause Written Advice Standard | International Tax Lawyer

Reliance on a written advice of a tax practitioner (attorney, CPA, etc.) may provide the basis for a reasonable cause exception to imposition of IRS noncompliance or late filing penalties with respect to pretty much every single US international tax compliance requirement. In this short article, I will describe the reasonable cause written advice standard […]

Banque Pictet Deferred Prosecution Agreement | Offshore Voluntary Disclosure Lawyer

On December 4, 2023, Banque Pictet et Cie SA (“Banque Pictet” – a Swiss private bank) entered into a deferred prosecution agreement with the US government. In this article, I will discuss Banque Pictet Deferred Prosecution Agreement and explain its importance. Banque Pictet Deferred Prosecution Agreement: Facts Leading Up to the Agreement The Pictet Group was […]

Minnesota Streamlined Disclosure Lawyer | International Tax Attorney

Minnesota has a sizable immigrant community with over 9% of the population foreign-born and another more than 7% of the population that has at least one immigrant parent. The top countries of original for immigrants are: Mexico, Somalia, India, Laos and Ethiopia. Many of these new US taxpayers own assets in foreign countries and receive income generated […]

Amarillo FBAR Attorney | International Tax Lawyer Texas

If you reside in Amarillo, Texas and have unreported foreign bank and financial accounts, you may be looking for a Amarillo FBAR Attorney.  Sherayzen Law Office, Ltd. is a leader in FBAR compliance, including offshore voluntary disclosures concerning delinquent FBARs, and you should consider us in your search. Let’s understand why this is the case. Amarillo FBAR Attorney: International […]