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On January 15, 2021, the IRS announced that the 2021 tax filing season for the tax year 2020 will start on Friday, February 12, 2021. On that day, the IRS will begin accepting and processing 2020 tax year returns. The February 12 start date for individual tax return filers allows the IRS time to do […]
On January 28, 2021, Mr. Eugene Sherayzen, an international tax attorney and founder of Sherayzen Law Office, Ltd., co-presented with a business lawyer a seminar titled “Investing in US Businesses by Foreign Persons – Common Business and Tax Considerations” (the “Inbound Transactions Seminar”). The Inbound Transactions Seminar was sponsored by the International Business Law Section […]
In a previous article, I described the analytical framework for conducting tax analysis of inbound transactions. In this article, I will focus on the first issue of this framework – the Non-US Person definition. Non-US Person Definition: Importance in the Context of Inbound Transactions Before we delve into the issue of Non-US Person definition, we […]
Inbound transactions deal with Non-US persons who operate in and/or derive income from the United States. This introductory essay opens a series of articles concerning US taxation of inbound transactions. Today, I will set forth the general inbound transactions tax framework; in future articles, I will explore in more detail each element of this framework. […]
2020 FBAR criminal penalties is a potential threat to any US taxpayer who willfully failed to file his FBARs or knowingly filed a false FBAR. In this essay, I would like to review the 2020 FBAR criminal penalties that these noncompliant US taxpayers may have to face. 2020 FBAR Criminal Penalties: Background Information A lot […]