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Ocultar dinero o activos en cuentas extranjeras no declaradas es un delito segun el Servicio de Impuestos Internos (“IRS”). De hecho, el IRS incluye cuentas extranjeras no declaradas en la lista de estafas tributarias “Docena sucia” del año 2019. Recopilada anualmente, la “Docena sucia” enumera una variedad de estafas comunes que los contribuyentes pueden encontrar […]
While there are a number of articles in professional publications and attorneys’ blogs covering the civil penalties associated with a failure to comply with the Foreign Account Tax Compliance Act (“FATCA”), there is almost a complete silence with respect to FATCA criminal penalties. This essay intends to fill this gap by introducing its readers to […]
On August 28, 2019, Mr. Eugene Sherayzen, the owner and founder of Sherayzen Law Office, Ltd, gave a seminar at Minsk City Bar Association (“MCBA”) in Minsk, Belarus. The focus of the seminar was on the 2017 Tax Cuts and Jobs Act (“2017 TCJA” or “2017 tax reform”) changes in the US international corporate tax […]
This article introduces readers to potential US international tax issues that a business entity may face when it elects to operate as a partnership for US tax purposes (all together “partnership international tax issues”). The focus of this article is on partnership international tax issues, particularly where US partnerships have a foreign partner and foreign […]
It seems that the IRS audit powers are increasing more and more at the expense of taxpayers’ privacy rights. In June of 2019, the IRS posted a procurement notice on its website to award a contract to a company Cellebrite, an Israeli company that specializes in smartphone decryption software and equipment. In other words, the […]