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Despite its appearances, the calculation of the Streamlined Domestic Offshore Procedures Title 26 Miscellaneous Offshore Penalty (“Streamlined Five Percent Offshore Penalty) may actually be a complex process. Moreover, the correct calculation of the Streamlined Five Percent Offshore Penalty may lead to some paradoxical conclusions, including a preference for the OVDP Penalty (now closed). Due to […]
A question that I would like to explore in this article is: Who is considered to be an Austin FBAR tax lawyer? It seems to be an odd question, because a lot of people would say that an Austin FBAR tax lawyer is an attorney who resides in Austin and does FBAR law. This, however, […]
If you are looking for a New York FBAR Lawyer, you should consider retaining the services of Mr. Eugene Sherayzen of Sherayzen Law Office, Ltd. While Mr. Sherayzen is not physically located in New York, he has a considerable number of clients in the City of New York and the State of New York. It […]
Over the years, the US tax treatment of foreign trusts has undergone dramatic changes. It is important to study and understand this history in order to properly understand and interpret current US tax laws concerning foreign trust. In this essay, I will provide a broad overview of the history of foreign trust tax treatment in […]