If you live in Orlando, Florida, and you are an owner or a beneficiary of a foreign trust, you need to secure the help of a Orlando Foreign Trust Attorney to properly comply with US international tax laws. You should consider retaining Sherayzen Law Office as your Orlando Foreign Trust Attorney. Sherayzen Law Office is […]
If you live in Miami, Florida, and you are an owner or a beneficiary of a foreign trust, you need to secure the help of a Miami Foreign Trust Attorney to properly comply with US international tax laws. You should consider retaining Sherayzen Law Office as your Miami Foreign Trust Attorney. Sherayzen Law Office is […]
If you reside in Athens, Georgia and have unreported foreign bank and financial accounts, you may be looking for a Athens 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. Athens FBAR Attorney: International […]
On August 21, 2024, the IRS announced that the Fourth Quarter 2024 IRS interest rates on overpayment and underpayment of tax will remain the same as in the Third Quarter of 2024. This means that, the Fourth Quarter 2024 IRS interest rates will be as follows: eight (8) percent for overpayments (seven (7) percent in the case of a corporation); eight (8) percent for underpayments; […]
If you live in Atlanta, Georgia, and you are an owner or a beneficiary of a foreign trust, you need to secure the help of a Atlanta Foreign Trust Attorney to properly comply with US international tax laws. You should consider retaining Sherayzen Law Office as your Atlanta Foreign Trust Attorney. Sherayzen Law Office is […]
If you reside in San Antonio, Texas, and have unreported foreign bank and financial accounts, you may be looking for a San Antonio FBAR Tax 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. […]
Passive Foreign Investment Company (PFIC) classification of a foreign corporation may have highly undesirable consequences for its US shareholders. In addition to high PFIC tax, these taxpayers face expensive and burdensome tax reporting requirements. This is why US taxpayers and their tax advisers generally try to avoid PFIC designation. This article explores a possible way […]
In the realm of US international tax compliance, few topics are as crucial as the reporting of foreign financial accounts, particularly The Foreign Bank and Financial Accounts Report (FBAR). This article focuses on one specific aspect of FBAR compliance: what accounts need to be disclosed on FBAR. In particular, we will delve into the intricacies of […]
If you reside in Knoxville, Tennessee and have unreported foreign bank and financial accounts, you may be looking for a Knoxville 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. Knoxville FBAR Attorney: International […]
If you reside in Fort Collins, Colorado, and have unreported foreign bank and financial accounts, you may be looking for a Fort Collins FBAR Tax 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. […]
If you reside in Chattanooga , Tennessee and have unreported foreign bank and financial accounts, you may be looking for a Chattanooga 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. Chattanooga […]
If you reside in Nashville, Tennessee and have unreported foreign bank and financial accounts, you may be looking for a Nashville 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. Nashville FBAR Attorney: International […]
If you reside in Colorado Springs, Colorado, and have unreported foreign bank and financial accounts, you may be looking for a Colorado Springs FBAR Tax 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. […]
Retaining a Corpus Christi foreign inheritance lawyer to deal with the IRS is very likely to be necessary if you reside in Corpus Christi, Texas and have received an inheritance from a non-resident alien (i.e. foreign inheritance). Sherayzen Law Office, Ltd. is a leader in US international tax compliance concerning foreign inheritance, including offshore voluntary disclosures concerning late disclosure of a foreign […]
If you reside in Glenview, Kentucky and have unreported foreign bank and financial accounts, you may be looking for a Glenview 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. Glenview FBAR Attorney: International […]
The Closer Connection Exception is a very important provision in US international tax law, because it provides a potential way for individuals who meet the Substantial Presence Test to still be treated as nonresident aliens for US income tax purposes. This article explores the Closer Connection Exception, its requirements and its implications for US and foreign taxpayers. Understanding the Closer […]
If you reside in Louisville, Kentucky and have unreported foreign bank and financial accounts, you may be looking for a Louisville 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. Louisville FBAR Attorney: International […]
The substantial presence test is one of the most important legal tests in the Internal Revenue Code (IRC), because it determines whether a person is a US tax resident solely by virtue of his physical presence in the United States. Additionally, this Test is essential to the determination of whether a person is a “US […]
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On June 28, 2024, the U.S. Department of the Treasury and the Internal Revenue Service (IRS) have issued final regulations requiring brokers to report sales and exchanges of digital assets, including cryptocurrency. These digital currency final regulations aim to improve tax compliance and provide taxpayers with necessary information for accurate tax reporting. Digital Currency Final […]
If you reside in Indianapolis, Indiana and have unreported foreign bank and financial accounts, you may be looking for a Indianapolis 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. Indianapolis FBAR Attorney: International […]
Retaining a Waco foreign inheritance lawyer to deal with the IRS is very likely to be necessary if you reside in Waco, Texas and have received an inheritance from a non-resident alien (i.e. foreign inheritance). Sherayzen Law Office, Ltd. is a leader in US international tax compliance concerning foreign inheritance, including offshore voluntary disclosures concerning late disclosure of a foreign inheritance, and […]
Retaining a Abilene foreign inheritance lawyer to deal with the IRS is very likely to be necessary if you reside in Abilene, Texas and have received an inheritance from a non-resident alien (i.e. foreign inheritance). Sherayzen Law Office, Ltd. is a leader in US international tax compliance concerning foreign inheritance, including offshore voluntary disclosures concerning late disclosure of a foreign inheritance, and […]
If you reside in Boulder, Colorado, and have unreported foreign bank and financial accounts, you may be looking for a Boulder FBAR Tax 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. Boulder […]
In the intricate realm of US international tax law, few areas are as challenging and potentially costly as PFIC compliance. Understanding the nuances of Passive Foreign Investment Companies (PFICs) is crucial for US taxpayers with foreign investments. This article provides an introduction to PFIC compliance, outlining key concepts and reporting requirements. What is PFIC Compliance? […]
Retaining a McKinney foreign inheritance lawyer to deal with the IRS is very likely to be necessary if you reside in McKinney, Texas and have received an inheritance from a non-resident alien (i.e. foreign inheritance). Sherayzen Law Office, Ltd. is a leader in US international tax compliance concerning foreign inheritance, including offshore voluntary disclosures concerning late disclosure of a foreign inheritance, and […]
Retaining a Dallas foreign inheritance lawyer to deal with the IRS is very likely to be necessary if you reside in Dallas, Texas and have received an inheritance from a non-resident alien (i.e. foreign inheritance). Sherayzen Law Office, Ltd. is a leader in US international tax compliance concerning foreign inheritance, including offshore voluntary disclosures concerning late disclosure of a foreign inheritance, and […]
US taxpayers must file Form 8938 with their US tax returns if they hold foreign financial assets with an aggregate value exceeding a relevant balance threshold. This article discusses the 2024 Form 8938 threshold limits. 2024 Form 8938 Threshold: Form 8938 Background Form 8938 burst onto the US international compliance scene in 2011 as a result […]
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Retaining a Austin foreign inheritance lawyer to deal with the IRS is very likely to be necessary if you reside in Austin, Texas and have received an inheritance from a non-resident alien (i.e. foreign inheritance). Sherayzen Law Office, Ltd. is a leader in US international tax compliance concerning foreign inheritance, including offshore voluntary disclosures concerning late disclosure of a foreign inheritance, and […]
Retaining a Houston foreign inheritance lawyer to deal with the IRS is very likely to be necessary if you reside in Houston, Texas and have received an inheritance from a non-resident alien (i.e. foreign inheritance). Sherayzen Law Office, Ltd. is a leader in US international tax compliance concerning foreign inheritance, including offshore voluntary disclosures concerning late disclosure of a foreign inheritance, and […]
Retaining a Minneapolis foreign inheritance lawyer to deal with the IRS is very likely to be necessary if you reside in Minneapolis, Minnesota and have received an inheritance from a non-resident alien (i.e. foreign inheritance). Sherayzen Law Office, Ltd. is a leader in US international tax compliance concerning foreign inheritance, including offshore voluntary disclosures concerning late […]
If you reside in Milwaukee, Wisconsin and have unreported foreign bank and financial accounts, you may be looking for a Milwaukee 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. Milwaukee FBAR Attorney: International […]
This article is an update of prior articles on the FBAR Civil Penalties. Since the US Congress mandated the IRS to adjust FBAR civil penalties for inflation on an annual basis, this article discusses the year 2024 FBAR Civil Penalties. 2024 FBAR Civil Penalties: Overview of the FBAR Penalty System FinCEN Form 114, the Report of Foreign Bank and […]
If you reside in Denver, Colorado, and have unreported foreign bank and financial accounts, you may be looking for a Denver FBAR Tax 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. Denver […]
On May 9, 2024, the IRS announced that the Third Quarter 2024 IRS interest rates on overpayment and underpayment of tax will remain the same as in the Second Quarter of 2024. This means that, the Third Quarter 2024 IRS interest rates will be as follows: Internal Revenue Code (“IRC”) §6621 establishes the IRS interest rates on overpayments and underpayments of tax. Under §6621(a)(1), the […]
On February 29, 2024, the IRS announced a major update to one of its compliance campaigns that focuses on high income non-filer taxpayers. Let’s discuss this major update to the High Income Non-filer IRS Campaign in more detail. High Income Non-Filer IRS Campaign: Background Information As part of its extensive tax enforcement planning in the […]
If you reside in Garland, Texas and have unreported foreign bank and financial accounts, you may be looking for a Garland FBAR Attorney. Sherayzen Law Office, Ltd. is a leader in FBAR compliance, including offshore voluntary disclosures concerning delinquent FBARs, consider us in your search. Let’s understand why this is the case. Garland FBAR Attorney: International Tax Lawyer First of […]
If you live in McKinney, Texas, and you are an owner or a beneficiary of a foreign trust, you need to secure the help of a McKinney Foreign Trust Attorney to properly comply with US international tax laws. You should consider retaining Sherayzen Law Office as your McKinney Foreign Trust Attorney. Sherayzen Law Office is […]
On February 21, 2024, the IRS announced that it will begin dozens of audits of business aircraft usage as part of a new tax enforcement campaign. In this short article, I will discuss these new IRS corporate jet audits in more detail. IRS Corporate Jet Audits: Focus on Personal Use of High-Net Individuals The IRS […]
On February 21, 2024, the IRS announced that the Second Quarter 2024 IRS interest rates on overpayment and underpayment of tax will remain the same as in the First Quarter of 2024. This means that, the Second Quarter 2024 IRS interest rates will be as follows: Internal Revenue Code (“IRC”) §6621 establishes the IRS interest rates on overpayments and underpayments of tax. Under §6621(a)(1), the overpayment […]
If you reside in McKinney, Texas and have unreported foreign bank and financial accounts, you may be looking for a McKinney 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. McKinney FBAR Attorney: International […]
If you live in Dallas, Texas, and you are an owner or a beneficiary of a foreign trust, you need to secure the help of a Dallas Foreign Trust Attorney to properly comply with US international tax laws. You should consider retaining Sherayzen Law Office as your Dallas Foreign Trust Attorney. Sherayzen Law Office is […]
If you reside in San Jose, California and have unreported foreign bank and financial accounts, you may be looking for a San Jose 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. San […]
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If you reside in Midland, Texas and have unreported foreign bank and financial accounts, you may be looking for a Midland 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. Midland FBAR Attorney: International […]
Sometimes, a taxpayer may find himself in a situation where his problem cannot be resolved through normal IRS channels. In this case, one of the options is to secure the help of the Taxpayer Advocate Service (“TAS”). TAS can issue a Taxpayer Assistance Order (TAO) to require the IRS to desist from a certain action […]
If you reside in Big Spring, Texas and have unreported foreign bank and financial accounts, you may be looking for a Big Spring 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. Big […]
One of the first things a client must get in order to pursue an offshore voluntary disclosure are all of the client records from his former accountant. Sometimes, however, the clients are having difficulty obtaining their documents from their accountants. In this article, I would like to briefly describe an accountant’s obligations with respect to […]
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 […]
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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 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 […]
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 […]
If you live in Abilene, Texas, and you are an owner or a beneficiary of a foreign trust, you need to secure the help of a Abilene Foreign Trust Attorney to properly comply with US international tax laws. You should consider retaining Sherayzen Law Office as your Abilene Foreign Trust Attorney. Sherayzen Law Office is […]
If you reside in Corpus Christi, Texas and have unreported foreign bank and financial accounts, you may be looking for a Corpus Christi 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. Corpus […]
Generally, only attorneys, CPAs, enrolled agents and enrolled actuaries can act as taxpayer representatives before the IRS. However, Circular 230 §10.7 contains several limited exceptions to this general requirement. Let’s explore these IRS limited practice exceptions. IRS Limited Practice Exceptions: Standard of Conduct Before we discuss the exceptions, I would like to point out that […]
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Internal Revenue Manual: Description & Purpose Internal Revenue Manual (“IRM”) is the primary, official source of IRS instructions to staff that relate to the administration and operation of the IRS. The rules set in the IRM are meant to provide guidance to the IRS employees (including managers) in their daily work life. The IRM is […]
If you reside in Abilene, Texas and have unreported foreign bank and financial accounts, you may be looking for a Abilene 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. Abilene FBAR Attorney: International […]
Florida has a huge immigrant community with over 21% of the population foreign-born and another more than 12% of the population that has at least one immigrant parent. The top countries of original for immigrants are: Cuba, Haiti, Colombia, Mexico and Jamaica. Many of these new US taxpayers own assets in foreign countries and receive income generated by […]
If you live in Waco, Texas, and you are an owner or a beneficiary of a foreign trust, you need to secure the help of a Waco Foreign Trust Attorney to properly comply with US international tax laws. You should consider retaining Sherayzen Law Office as your Waco Foreign Trust Attorney. Sherayzen Law Office is […]
In this calender year 2024, there is a special October 7 FBAR deadline that was created by FinCEN in response to the October 7 terrorist attack against Israel. Let’s discuss discuss this special October 7 FBAR deadline in more detail. October 7 FBAR Deadline: Background Information The terrorist attack on Israel on October 7, 2023 […]
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If you reside in Waco, Texas and have unreported foreign bank and financial accounts, you may be looking for a Waco FBAR Attorney. Sherayzen Law Office, Ltd. is a leader in FBAR compliance, including offshore voluntary disclosures concerning delinquent FBARs, consider us in your search. Let’s understand why this is the case. Waco FBAR Attorney: International Tax Lawyer First of […]
On January 16, 2024, the IRS Large Business and International division announced a new compliance campaign: the IRS Sports Industry Campaign. While the announcement is recent and certain details are not yet available, let’s discuss the general direction of this IRS new compliance tax enforcement effort. IRS Sports Industry Campaign: Background Information In the mid-2010s, after […]
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On January 22, 2024, the Internal Revenue Service announced tax relief for individuals and businesses in parts of Connecticut affected by severe storms, flooding and a potential dam breach that began on January 10, 2024. These taxpayers now have until June 17, 2024, to file various federal individual and business tax returns and make tax payments. June […]
Oklahoma is a home to a growing immigrant community with at least 6% of the population foreign-born and another 6% of the population that has at least one immigrant parent. The top countries of original for immigrants are: Mexico, Vietnam, India, Germany (a major surprise to many people) and Guatemala. Many of these new US taxpayers own […]
If you live in Plano, Texas, and you are an owner or a beneficiary of a foreign trust, you need to secure the help of a Plano Foreign Trust Attorney to properly comply with US international tax laws. You should consider retaining Sherayzen Law Office as your Plano Foreign Trust Attorney. Sherayzen Law Office is […]
If you reside in Houston, Texas and have unreported foreign bank and financial accounts, you may be looking for a Houston FBAR Attorney. Sherayzen Law Office, Ltd. is a leader in FBAR compliance, including offshore voluntary disclosures concerning delinquent FBARs, consider us in your search. Let’s understand why this is the case. Houston FBAR Attorney: International Tax Lawyer First of […]
On November 17, 2023, the IRS announced that the First Quarter 2024 IRS interest rates on overpayment and underpayment of tax will not change from the Fourth Quarter of 2023. This means that, the First Quarter 2024 IRS interest rates will be as follows: Internal Revenue Code (“IRC”) §6621 establishes the IRS interest rates on overpayments and underpayments of tax. Under §6621(a)(1), […]
An increasing number of submissions under the Streamlined Domestic Offshore Procedures (SDOP) has been subject to an IRS audit; this trend will undoubtedly continue in 2024. In this article, I will explain what an 2024 SDOP Audit is and what a taxpayer should expect during the Audit. 2024 SDOP Audit: Background Information on Streamlined Domestic Offshore Procedures Streamlined Domestic […]
If you live in Minneapolis, Minnesota, and you are an owner or a beneficiary of a foreign trust, you need to secure the help of a Minneapolis Foreign Trust Attorney to properly comply with US international tax laws. You should consider retaining Sherayzen Law Office as your Minneapolis Foreign Trust Attorney. Sherayzen Law Office is […]
If you reside in Denver, Colorado and have unreported foreign bank and financial accounts, you may be looking for a Denver FBAR Attorney. Sherayzen Law Office, Ltd. (“Sherayzen Law Office”) is a leader in FBAR compliance and you should consider us in your search. Let’s understand why this is the case. Denver FBAR Attorney: International Tax Lawyer First of all, it […]
Since 2014, Streamlined Domestic Offshore Procedures (“SDOP”) has probably been the most popular offshore voluntary disclosure option, and I predict that it will remain so in the year 2024. In this article, I would like to explore main four 2024 SDOP advantages which US taxpayers should take into account while considering an offshore voluntary disclosure this year. 2024 […]
Indiana is a home to a small but growing immigrant community with at least 5% of the population foreign-born and another 5% of the population that has at least one immigrant parent. The top countries of original for immigrants are: Mexico, India, China, Myanmar and the Philippines. Many of these new US taxpayers own assets in foreign countries and […]
If you reside in Cambridge, Massachusetts and have unreported foreign bank and financial accounts, you may be looking for a Cambridge FBAR Attorney. Sherayzen Law Office, Ltd. (“Sherayzen Law Office”) is a leader in FBAR compliance and you should consider us in your search. Let’s understand why this is the case. Cambridge FBAR Attorney: International Tax Lawyer First of all, it […]
The introduction of the Streamlined Domestic Offshore Procedures (SDOP) in 2014 meant that the IRS finally recognized that there was a very large number of U.S. taxpayers who were non-willful with respect to their inability to comply with numerous obscure complex requirements of U.S. tax laws. Since 2014, SDOP has been a highly successful voluntary disclosure option that […]
Ohio has a growing immigrant community with at least 5% of the population foreign-born and another 5% of the population that has at least one immigrant parent. The top countries of original for immigrants are: India, Mexico, China, the Philippines and Canada; more than half of them are naturalized US citizens and more than 42% of them […]
If you reside in Worcester, Massachusetts, and you have unreported foreign bank and financial accounts, you may be looking for Worcester FBAR Attorney. In your search, please consider Mr. Eugene Sherayzen of Sherayzen Law Office, Ltd. (“Sherayzen Law Office”). Let’s understand why this is the case. Worcester FBAR Attorney: International Tax Lawyer First of all, it is very important to […]
Wisconsin has a small but rapidly growing immigrant community with at least 5% of the population foreign-born and another 5% of the population that has at least one immigrant parent. The top countries of original for immigrants are: Mexico, India, China, Laos and the Philippines. Many of these new US taxpayers own assets in foreign countries […]
Beginning January 1, 2024, the IRS changed the optional standard mileage for the calculation of deductible costs of operating an automobile (sedans, vans, pickups and panel trucks) for business, charitable, medical or moving purposes. Let’s discuss in more detail these new 2024 IRS Standard Mileage Rates. 2024 IRS Standard Mileage Rates for Business Usage For the tax year 2024, […]
If you reside in Boston, Massachusetts, and you have unreported foreign bank and financial accounts, you may be looking for Boston FBAR Attorney. In your search, please consider Mr. Eugene Sherayzen of Sherayzen Law Office, Ltd. (“Sherayzen Law Office”). Let’s understand why this is the case. Boston FBAR Attorney: International Tax Lawyer First of all, it is very important to […]
On December 21, 2023, the IRS and the US Department of Justice announced that Mr. Rolf Schnellmann, a Swiss national, pleaded guilty to conspiring to defraud the United States for his role in the creation and implementation of a fraud scheme related to foreign accounts and foreign income called “Singapore Solution”. In this small essay, I […]
If you reside in Duluth, Minnesota, and you have unreported foreign bank and financial accounts, you may be looking for Duluth FBAR Attorney. In your search, please consider Mr. Eugene Sherayzen of Sherayzen Law Office, Ltd. (“Sherayzen Law Office”). Let’s understand why this is the case. Duluth FBAR Attorney: International Tax Lawyer First of all, it is very important to […]
The 2023 FBAR conversion rates are very important for your US international tax compliance. The reason for their importance is their relation to FBAR (FinCEN Form 114) and the IRS Form 8938. The 2023 FBAR and 2023 Form 8938 instructions both require that 2023 FBAR conversion rates be used to report the required highest balances of foreign financial assets on these […]
If you reside in St Paul, Minnesota, and you have unreported foreign bank and financial accounts, you may be looking for St Paul FBAR Attorney. In your search, please consider Mr. Eugene Sherayzen of Sherayzen Law Office, Ltd. (“Sherayzen Law Office”). Let’s understand why this is the case. St Paul FBAR Attorney: International Tax Lawyer First of all, it is […]
Form 5471 generally requires US GAAP (Generally Accepted Accounting Practices) conversion of foreign financial statements for the purposes of reporting book income, because foreign accountants usually prepare these statements based on a different foreign standard. While Treas. Reg. Reg. §1.964-1(a)(2) contains a limited exception to the US GAAP conversion adjustments for “non-material” items (the same exception applies to […]
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If you reside in Plano, Texas, and you have unreported foreign bank and financial accounts, you may be looking for Plano FBAR Attorney. In your search, please consider Mr. Eugene Sherayzen of Sherayzen Law Office, Ltd. (“Sherayzen Law Office”). Let’s understand why this is the case. Plano FBAR Attorney: International Tax Lawyer First of all, it is very important to […]
If you are a resident of Galveston, Texas, and you have unreported foreign bank and financial accounts, you may be looking for Galveston FBAR Attorney. In your search, consider Mr. Eugene Sherayzen of Sherayzen Law Office, Ltd. (“Sherayzen Law Office”). Let’s understand why this is the case. Galveston FBAR Attorney: International Tax Lawyer First of all, it is […]
If you are a resident of Sugar Land (Texas) and you have unreported foreign bank and financial accounts, you may be looking for Sugar Land FBAR Attorney in Texas. In your search, you should consider Mr. Eugene Sherayzen of Sherayzen Law Office, Ltd. (“Sherayzen Law Office”). Let’s understand why this is the case. Sugar Land FBAR Attorney: International […]
If you are a resident of The Woodlands (Texas) and you have unreported foreign accounts, you may be looking for The Woodlands FBAR Attorney in Texas. In your search, you should consider Mr. Eugene Sherayzen of Sherayzen Law Office, Ltd. (“Sherayzen Law Office”). Let’s explore in more detail why this is the case. The Woodlands FBAR Attorney: International […]
Failure to timely and correctly submit Form 5471 with a US tax return may lead to an imposition of Form 5471 penalties. In this article, I will discus the most important 2024 Form 5471 penalties that US taxpayers may face if they fail to comply with the Form 5471 requirements. 2024 Form 5471 Penalties: Purpose of Form 5471 We first need to understand […]
As was the case in the year 2023, I expect that Streamlined Domestic Offshore Procedures will continue to be the flagship offshore voluntary disclosure option in 2024 for US taxpayers who reside in the United States. This is why noncompliant US taxpayers should understand well the main advantages and disadvantages of participating in the 2024 Streamlined Domestic […]
Dear clients, followers, readers and colleagues: Mr. Eugene Sherayzen, an international tax attorney, and the entire international tax team of Sherayzen Law Office, Ltd. wishes you a very Happy New Year 2024!!! Dear clients and prospective clients, in the New Year 2024, you can continue to rely on Sherayzen Law Office for: In resolving all of your current […]
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If you are looking for a Minnesota FBAR tax attorney, consider retaining the services of Mr. Eugene Sherayzen of Sherayzen Law Office, Ltd. (“Sherayzen Law Office”). Mr. Sherayzen is an international tax attorney and founder of Sherayzen Law Office. Minnesota FBAR tax attorney: FBAR Specialization of an International Tax Attorney The definition of a Minnesota FBAR tax attorney includes […]
Form 3520-A is a very important US international information return. It can be very complex and has somewhat tricky filing requirements as well as significant noncompliance penalties. In order to avoid these penalties, you need to file a correct Form 3520-A timely. In this essay, I will discuss the 2023 Form 3520-A deadline in the calendar year 2024. 2023 Form 3520-A Deadline: […]
Form 3520 is one of the most important US international information returns. Due to its severe penalty structure, it is important to file it timely. In this brief essay, I will discuss the tax year 2023 Form 3520 deadline. 2023 Form 3520 Deadline: What is Form 3520 IRS Form 3520 is a US international information return used by the IRS to collect […]
IRS Form 5471 is one of the most important US international information returns. In this brief essay, I will discuss the tax year 2023 Form 5471 deadline in the calendar year 2024. 2023 Form 5471 Deadline: What is Form 5471 Form 5471 is a US international information return. In general, the IRS uses Form 5471 to collect information about certain US persons who are officers, directors, or shareholders in […]
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The 2023 FBAR deadline is a critical deadline for US taxpayers this calendar year 2024. What makes FBAR so important are the draconian FBAR penalties which may be imposed on noncompliant taxpayers. Let’s discuss the 2023 FBAR deadline in more detail. 2023 FBAR Deadline: Background Information The official name of FBAR is FinCEN Form 114, the Report of Foreign Bank and Financial Accounts. US […]
Streamlined Foreign Offshore Procedures has been the best voluntary disclosure option since its creation in 2014 for eligible US taxpayers with undisclosed foreign assets and foreign income, and I predict that it will remain so in the year 2024. Let’s discuss in more detail the unique advantages of the 2024 Streamlined Foreign Offshore Procedures. 2024 Streamlined Foreign Offshore Procedures: Background […]
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Even as the year 2023 nears its end, numerous taxpayers continue to be substantially noncompliant with various US international tax laws. Hence, it is important for US taxpayers with undisclosed foreign assets to consider their 2024 offshore voluntary disclosure options. In this essay, I would like to provide an overview of these 2024 offshore voluntary disclosure options. 2024 Offshore Voluntary Disclosure […]
The 2023 IRS quarterly interest rates IRS interest rates are relevant for a great variety of purposes. Let’s highlight three of its most important uses. First, these rates will determine the interest a taxpayer will get on any IRS refunds. Second, the 2023 IRS quarterly interest rates will also be used to establish the interest […]
US taxpayers with undisclosed foreign assets and foreign income need to consider their 2023 offshore voluntary disclosure options. As was the case in the year 2022, I expect that Streamlined Domestic Offshore Procedures will continue to be the flagship voluntary disclosure option in 2023 for US taxpayers who reside in the United States. This is […]
Child FBAR filing obligations is a topic that comes up fairly often in my practice. In this short essay, I will discuss whether a child is required to file an FBAR and how it should be done. Child FBAR Obligations: What is FBAR FBAR is a common abbreviation for the Report of Foreign Bank and […]
In my practice, I often receive calls from people who are confused about their FBAR obligations. A recent call raised an important issue of whether a tax treaty election may affect one’s FBAR obligations. In this brief article, I would like to address this issue of tax treaty election FBAR obligations.
FinCEN Form 114 US Person definition is a highly important component of FBAR and US international tax compliance. In this essay, I will discuss in detail the FinCEN Form 114 US Person definition and highlight some common issues that arise with respect to this definition.
The 2022 FBAR conversion rates are very important for your US international tax compliance. The reason for their importance is their relation to FBAR (FinCEN Form 114) and the IRS Form 8938. The 2022 FBAR and 2022 Form 8938 instructions both require that 2022 FBAR conversion rates be used to report the required highest balances […]
On December 12, 2022, the Internal Revenue Service reminded those who were born in 1950 or earlier that funds in their retirement plans and individual retirement arrangements face important upcoming deadlines for the 2022 required minimum distributions to avoid penalties. What are the 2022 Required Minimum Distributions? Required minimum distributions, or RMDs, are minimum amounts […]
On August 15, 2022, the IRS announced that the 2022 Fourth Quarter IRS interest rates will again increase for both underpayment and overpayment cases. This increase closely follows the Federal Reserve’s recent increases in interest rates. This means that, the 2022 Fourth Quarter IRS interest rates will be as follows: Under the Internal Revenue Code, […]
One of the most challenging issues during an IRS audit is establishing cost-basis in foreign real estate. This issue most frequently comes up in the context of real estate that was obtained through inheritance or gift many years ago. In this article, based on my IRS audit experiences, I would like to discuss the main […]
In situations where a person was not classified as a resident alien at any time in the preceding calendar year and he became a resident alien at some point during current year, a question often arises concerning the tax residency starting date of such a person. This article seeks to provide a succinct overview of […]
On February 23, 2022, the Internal Revenue Service (“IRS”) announced that the 2022 Second Quarter IRS underpayment and overpayment interest rates (“2022 2Q IRS Interest Rates”) will increase from the first quarter of 2022. This means that, the 2022 2Q IRS interest rates will be as follows: The second quarter will start on April 1, […]
On February 22, 2022, Mr. Eugene Sherayzen, an international tax attorney and founder of Sherayzen Law Office, Ltd., presented at a seminar “IRS Voluntary Disclosure Options for U.S. Owners of a Foreign Business” (the “Offshore Voluntary Disclosure Seminar”). The Offshore Voluntary Disclosure Seminar was sponsored by the International Business Law Section of the Minnesota State […]
In early February of 2022, Mr. Sherayzen, an international tax attorney and owner of Sherayzen Law Office, Ltd., traveled to Austin, Texas. Let’s discuss this Austin business trip in more detail. Austin Business Trip: Goals While the business trip to Austin was very short, Mr. Sherayzen set forth three main goals for the trip: (1) […]
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Form 3520-A is a very important US international information return. It can be very complex and has somewhat tricky filing requirements as well as significant noncompliance penalties. In order to avoid these penalties, you need to file a correct Form 3520-A timely. In this essay, I will discuss the 2021 Form 3520-A deadline in the […]
Austin is a fast-growing city which attracts a large number of immigrants with assets in foreign countries. These assets may also generate foreign income which their owners must disclose on their US tax returns. Unfortunately many of these new residents of Austin have not correctly reported their foreign assets and foreign income to the IRS. […]
IRS Form 5471 is one of the most important US international information returns. In this brief essay, I will discuss the tax year 2021 Form 5471 deadline in the calendar year 2022. 2021 Form 5471 Deadline: What is Form 5471 Form 5471 is a US international information return. In general, the IRS uses Form 5471 […]
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The beginning of a new tax season starts the clock on completing the required US international information returns, including Form 3520. In this brief essay, I will discuss the tax year 2021 Form 3520 deadline. 2021 Form 3520 Deadline: What is Form 3520 ? IRS Form 3520 is a US international information return used by […]
The 2021 FBAR deadline is a critical deadline for US taxpayers this calendar year 2022. What makes FBAR so important are the draconian FBAR penalties which may be imposed on noncompliant taxpayers. Let’s discuss the 2021 FBAR deadline in more detail. 2021 FBAR Deadline: Background Information The official name of FBAR is FinCEN Form 114, […]
While the year 2021 has ended, numerous taxpayers continue to be substantially noncompliant with various US international tax laws. Hence, it is important for US taxpayers with undisclosed foreign assets to consider their 2022 offshore voluntary disclosure options. In this essay, I would like to provide an overview of these 2022 offshore voluntary disclosure options. […]
If you have foreign financial accounts and reside in San Antonio (Texas), you would be looking for a San Antonio FBAR Attorney in Texas. In your search, you could consider out-of-state attorneys such as Mr. Eugene Sherayzen of Sherayzen Law Office, Ltd. (“Sherayzen Law Office”). Let’s explore in more detail why this is the case. […]
The 2021 FBAR conversion rates are highly important in US international tax compliance. The 2021 FBAR and 2021 Form 8938 instructions both require that 2021 FBAR conversion rates be used to report the required highest balances of foreign financial assets on these forms (in the case of Form 8938, the 2021 FBAR conversion rates is […]
If you have foreign financial accounts and reside in San Diego (California), you would be looking for a San Diego FBAR Attorney in California. In your search, you could consider out-of-state attorneys such as Mr. Eugene Sherayzen of Sherayzen Law Office, Ltd. (“Sherayzen Law Office”). Let’s explore in more detail why this is the case. […]
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In a previous article, I discussed the necessity of balancing international tax planning priorities in order to obtain an optimal tax result. In this article, I will explain why international tax planning should be based on a carefully-studied factual basis. Factual Basis as the Foundation for International Tax Planning Young inexperienced lawyers often come up […]
If you have foreign financial accounts and reside in Los Angeles (California), you would be looking for a Los Angeles FBAR Attorney in California. In your search, you might consider out-of-state attorneys such as Mr. Eugene Sherayzen of Sherayzen Law Office, Ltd. (“Sherayzen Law Office”). Let’s explore in more detail why this is the case. […]
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For the purposes of US international tax laws, it is very important to distinguish a subsidiary from a branch. Let’s define both terms in this short essay. Subsidiary vs. Branch: Definition of a Branch A branch is a direct form of doing business by a corporation in another country where the corporation retains the direct […]
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If you have foreign financial accounts and reside in San Francisco (California), you should be looking for a San Francisco FBAR Attorney in California. In your search, you could consider out-of-state attorneys such as Mr. Eugene Sherayzen of Sherayzen Law Office, Ltd. (“Sherayzen Law Office”). Let’s explore in more detail why this is the case. […]
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Sometimes, I encounter in my practice one particularly damaging belief concerning international tax planning for US corporations that engage in cross-border transactions and maintain a foreign subsidiary or a network of foreign subsidiaries. This is a belief that international tax planning for such corporations should only focus on the reduction of its US taxes above […]
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Defining a partnership as “foreign” or “domestic” can be highly important for US tax purposes. In this article, I will explain the foreign partnership definition and explain its significance. Foreign Partnership Definition: Importance There may be important US international tax law consequences that stem from whether a partnership is classified as “foreign” or “domestic”. These […]
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If you have foreign financial accounts and reside in Berkeley (California), you would be looking for a Berkeley FBAR Attorney in California. In your search, consider out-of-state attorneys such as Mr. Eugene Sherayzen of Sherayzen Law Office, Ltd. (“Sherayzen Law Office”). Let’s explore in more detail why this is the case. Berkeley FBAR Attorney: International […]
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Dear clients, followers, readers and colleagues: Sherayzen Law Office wishes you a very Happy New Year 2022!!! For those of you who are currently not in compliance with their US international tax reporting obligations, including FBAR or FinCEN Form 114, we wish you to successfully resolve your prior noncompliance in this new year 2022 with […]
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If you reside in Oakland (California) and have foreign accounts, you would be looking for a Oakland FBAR Attorney in California. In your search, consider out-of-state attorneys such as Mr. Eugene Sherayzen of Sherayzen Law Office, Ltd. (“Sherayzen Law Office”). Let’s explore in more detail why this is the case. Oakland FBAR Attorney: International Tax […]
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If you are a resident of Sacramento (California) and you have foreign accounts, you would be looking for a Sacramento FBAR Attorney in California. In your search, you could consider out-of-state attorneys such as Mr. Eugene Sherayzen of Sherayzen Law Office, Ltd. (“Sherayzen Law Office”). Let’s explore in more detail why this is the case. […]
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If you are looking for a Bozeman FBAR Attorney in Montana, the recommendation is that you retain the services of Mr. Eugene Sherayzen of Sherayzen Law Office, Ltd. (“Sherayzen Law Office”). Mr. Sherayzen is an FBAR Attorney and founder of Sherayzen Law Office. Bozeman FBAR Attorney: International Tax Attorney It is very important to understand […]
Oregon is a lovely state which hosts a number of immigrants from many different countries (especially in Portland, but also Salem and Eugene). Many of these new US taxpayers own assets in foreign countries and receive income generated by these assets. Unfortunately a number of these taxpayers are not in compliance with their US international […]
This essay seeks to identify those considered to be a “US Taxpayer” with respect to reporting foreign real estate or income from it to the IRS. In other words, today, I will discuss the foreign real estate US Taxpayer definition. Foreign Real Estate US Taxpayer Definition: IRC §7701(a) The definition of “US taxpayer” for the […]
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Failure to timely and correctly submit Form 5471 with a US tax return may lead to an imposition of Form 5471 penalties. In this article, I will discus the most important 2022 Form 5471 penalties that US taxpayers may face if they fail to comply with the Form 5471 requirements. 2022 Form 5471 Penalties: Purpose […]
Streamlined Foreign Offshore Procedures has been the best voluntary disclosure option for eligible US taxpayers with undisclosed foreign assets and foreign income, and I predict that it will remain so in the year 2022. Let’s discuss in more detail the unique advantages of the 2022 Streamlined Foreign Offshore Procedures. 2022 Streamlined Foreign Offshore Procedures: Background […]
Florida is one of the most favorite destinations for immigrants as well as US citizens who do business overseas. Many of these taxpayers own assets in foreign countries and receive income generated by these assets. For this reason, Florida is also one of the leading states when it comes to individuals who wish to go […]
As the year 2021 winds down, US taxpayers with undisclosed foreign assets and foreign income need to consider their 2022 offshore voluntary disclosure options. As it has been the case since the second half of 2014 (really the year 2018 when the 2014 OVDP was closed), I expect that Streamlined Domestic Offshore Procedures will continue […]
The increased emigration to Texas of foreigners and Americans from other states resulted in a higher portion of Texans with undisclosed foreign assets. The vast majority of these Texans are non-willful with respect to their prior reporting noncompliance and, once they discover their prior noncompliance, they look for professional help resolve their US tax noncompliance […]
If you are a California resident with undisclosed foreign assets and you believe that you were non-willful with respect to your prior reporting noncompliance, you would be looking for professional help to bring your US tax affairs into full compliance with US international tax law through Streamlined Domestic Offshore Procedures. In other words, you are […]
If you have undisclosed foreign accounts and you are a resident of Spring, Texas, it is important for you to understand your options in terms of who can help you with the voluntary disclosure of your noncompliant offshore accounts. In this article, I will help you understand your offshore accounts voluntary disclosure lawyer Spring Texas […]
On November 23, 2021, the IRS announced that the First Quarter 2022 IRS interest rates on overpayment and underpayment of tax will not change from the Fourth Quarter of 2021. This means that, the First Quarter 2022 IRS interest rates will be as follows: Internal Revenue Code (“IRC”) §6621 establishes the IRS interest rates on […]
Ownership of a Controlled Foreign Corporation (“CFC”) presents unique income tax challenges under US international tax law. One of them is the fact that US shareholders of a CFC may have to recognize CFC income on their US tax returns beyond what is required under US domestic tax laws. In this article, I will introduce […]
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It is a common, almost default practice in Brazil to invest in Brazilian mutual funds. While this practice is perfectly innocent for majority of Brazilians, it may present a huge compliance issue for Brazilians who are also US taxpayers. The problem is that this type of an investment draws at least two important US tax […]
As if they were not high enough, the US Congress has obligated the IRS to adjust FBAR civil penalties for inflation on an annual basis. In this article, I will provide a broad overview of the current FBAR penalty system and describe the current 2021 FBAR civil penalties. 2021 FBAR Civil Penalties: Overview of the […]
After having handled so many offshore voluntary disclosures for my Indian and Indian-American clients, I can clearly see that US tax reporting obligations concerning Indian mutual funds is one of the most troublesome areas for my clients. In this article, I will focus on the three most important US tax reporting requirements that may be […]
The 2020 FBAR conversion rates are highly important in US international tax compliance. The 2020 FBAR and 2020 Form 8938 instructions both require that 2020 FBAR conversion rates be used to report the required highest balances of foreign financial assets on these forms (in the case of Form 8938, the 2020 FBAR conversion rates is […]
The 2020 FBAR deadline is one of the most important deadlines for US taxpayers this calendar year 2021. What makes FBAR so important are the draconian FBAR penalties which may be imposed on noncompliant taxpayers. Let’s discuss the 2020 FBAR deadline in more detail. 2020 FBAR Deadline: Background Information The official name of FBAR is […]
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 […]
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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 […]
I often receive calls from prospective clients who talk about FBAR voluntary disclosure. They usually have no clear idea of what is meant by this term and what its requirements are. In this article, I will discuss this concept of FBAR Voluntary Disclosure and explain how this concept covers a variety of offshore voluntary disclosure […]
Recently, I received a number of phone calls and emails from people who complained about incorrect filing of their Streamlined Domestic Offshore Procedures (“SDOP”) packages by lawyers who took their cases on a flat-fee basis. In this article, I would like to discuss why a flat fee is generally not well-suited for a proper SDOP […]
US taxpayers can still timely file their 2019 FBAR (Report of Foreign Bank and Financial Accounts) by the new October 31 2020 FBAR deadline. This FBAR deadline extension is highly unusual and requires some explanation. October 31 2020 FBAR Deadline: What is FBAR? The Report of Foreign Bank and Financial Accounts (“FBAR”) is officially known […]
This article is a second installment of our series of articles on corporate distributions. Today’s topic is the description of 26 U.S.C. Subpart A, which contains the most important tax provisions for our subsequent discussions of this subject. 26 U.S.C. Subpart A: Purpose 26 U.S.C Subpart A is the first part of Part I of […]
This essay opens our new series of articles which focuses on corporate distributions. The new series will cover the classification, statutory structure and tax treatment of various types of corporation distributions, including redemptions of corporate stock. This first article seeks to introduce the readers to the overall US statutory tax structure concerning corporate distributions. Corporation […]
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On March 5, 2020, the Internal Revenue Service (“IRS”) and the U.S. Department of Justice (“DOJ”) announced that Mr. Oleg Tinkov was arrested in London in connection with an indictment concerning concealment of about $1 billion in foreign assets and the expatriation income in connection with these assets. Let’s discuss the Tinkov case in more […]
In a previous article, I discussed the IRC (Internal Revenue Code) §318 sidewise attribution limitation. This limitation was the last piece in the jigsaw puzzle of the §318 entity-member attribution rules; now, we are ready to summarize these rules in light of this exception. This is the purpose of this article – state the §318 […]
On April 9, 2020, the IRS announced additional relief to taxpayers by moving the due date for more deadlines to July 15, 2020. Let’s discuss this additional July 15 Deferral in more detail. July 15 Deferral: Background Information On March 13, 2020, in response to the 2019 coronavirus (also called “COVID-19″) pandemic, President Trump issued […]
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On March 31, 2020, the IRS launched the Employee Retention Credit. This new tax credit is designed to encourage businesses to keep employees on their payroll. Let’s discuss the Employee Retention Credit in more detail. Employee Retention Credit: Eligibility Criteria Two categories of employers are not eligible to apply for the Employee Retention Credit: (a) […]
This article explores the third main limitation on the general IRC (Internal Revenue Code) §318 corporate stock re-attribution rules – §318 Sidewise Attribution Limitation. §318 Sidewise Attribution Limitation: What is “Sidewise Attribution”? A sidewise attribution occurs when corporate stock owned by an owner of a business entity (or a beneficiary of a trust or estate) […]
On March 25 , 2020, the Honorable Tim Walz, Governor of the State of Minnesota, issued a “Shelter-In-Place” Emergency Executive Order 20-20. The Executive Order mandates all persons in Minnesota to stay at home or in their place residence, unless they go out to engage in certain activities or do work for a business which […]
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The advancement of coronavirus in the United States and around the world has significantly disrupted the normal conditions and assumptions for a US taxpayer who engages in an offshore voluntary disclosure of his unreported foreign income and foreign assets. I will refer to a voluntary disclosure conducted in this context of the coronavirus disruptions as […]
On March 21, 2020, the IRS moved the federal income tax filing and tax payment due date from April 15, 2020, to July 15, 2020. Let’s discuss the new July 15 deadline in more detail. July 15 Deadline: Why the IRS Moved the Tax Deadline to July 15, 2020? The IRS moved the deadline because […]
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The ongoing coronavirus pandemic has disrupted many areas of human activity around the planet. The coronavirus even affected the IRS offshore voluntary disclosures concerning US taxpayers’ unreported financial assets and income in China (“Chinese Offshore Voluntary Disclosures”). In fact, the impact of coronavirus on the Chinese Offshore Voluntary Disclosures has been severe and extremely disruptive. […]
This article explores the second limitation on the IRC (Internal Revenue Code) §318 re-attribution rule – family re-attribution limitation. Family Re-Attribution Limitation: General §318 Re-Attribution Rule The general §318 re-attribution rule states that a constructively-owned corporate stock should be treated as actually owned for the purpose of further re-attribution of stock to other persons. §318(a)(5)(A). […]
This article continues a series of articles concerning US tax classification of unusual foreign entities; our focus is on the determination whether these entities should be classified as foreign business entities or foreign trusts. Today’s topic is the Hindu Undivided Family, the preferred legal entity for managing family estates for a large number of wealthy […]
In a previous article, I discussed the IRC (Internal Revenue Code) §318 general rule on the re-attribution of corporate stock; in that context, I mentioned that there are certain restrictions on §318 re-attribution. Today, I would like to discuss one of such restrictions – §318 double-inclusion prohibition. §318 Double-Inclusion Prohibition: General Re-Attribution Rule Before we […]
On February 28, 2020, the Internal Revenue Service (“IRS”) announced that the 2020 Second Quarter IRS underpayment and overpayment interest rates (“2020 2Q IRS Interest Rates”) will not change from the first quarter of 2020. This means that, the 2020 2Q IRS interest rates will be as follows: Under the Internal Revenue Code, these interest […]
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In an earlier article, I discussed the advantages of the Streamlined Domestic Offshore Procedures (“SDOP”) in the year 2020. Among the advantages, I mentioned the SDOP Miscellaneous Offshore Penalty (hereinafter “SDOP Penalty”), but never explained this concept. The focus of this article is on the 2020 SDOP Penalty and how one generally should calculate it. […]
This article continues a series of articles on the Internal Revenue Code (“IRC”) §318 constructive ownership rules. Today, I would like to focus on the §318 re-attribution rule. In this article, I will explain the general §318 re-attribution rule and mention the exceptions. I will discuss the exceptions in more detail in future articles. §318 […]
This article continues a series of articles on foreign trust classification with respect to various foreign entities. Today’s topic is the US tax treatment of a Liechtenstein Stiftung. Liechtenstein Stiftung: Formation A Liechtenstein Stiftung, or Foundation, is a legal entity under Liechtenstein law. It may be formed by filing a foundation charter or by will […]
Over the years, the IRS has made a number of rulings with respect to whether certain foreign entities should be considered trusts for US tax purposes. In this article, I would like to discuss the US tax classification of Liechtenstein Anstalt based on the 2009 IRS Chief Counsel Advice Memorandum, AM 2009-012. Liechtenstein Anstalt: Creation […]
For the very first time, the IRS has created a new tax form called Form “1040-SR”. “SR” here standards for “seniors”. The idea is that the new form will be used by senior taxpayers. Let’s discuss Form 1040-SR in more detail. Form 1040-SR: Reasons for Its Creation The reason for the creation of Form 1040-SR […]
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FinCEN Form 114 trust filers constitute a highly problematic category of FBAR filers. Form 114 trust filers are problematic not so much because the FBAR requirement itself is unclear, but, rather, because the trustees do not realize that this requirement applies to them. In this article, I would like to educate potential Form 114 trust […]
A previous article defined “option” for the purposes of the IRC (Internal Revenue Code) §318(a)(4). Today, I will discuss the main §318 option attribution rule. §318 Option Attribution: Main Rule Under §318(a)(4), “if any person has an option to acquire stock, such stock shall be considered as owned by such person.” For the purposes of […]
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This article continues our series of articles on the IRC (Internal Revenue Code) §318 constructive ownership rules. In this article, I would like to introduce the readers to the infamous §318 option attribution rules. Before we delve into the discussion of the constructive ownership rules for options, however, it is important to understand what “option” […]
In a previous article, I discussed the rules for the downstream attribution of corporate stocks under the IRC (Internal Revenue Code) §318. Today, I would like to discuss the §318 upstream corporate attribution rules. §318 Upstream Corporate Attribution: Two Types of Attribution There are two types of §318 corporate attribution rules: downstream and upstream. Under […]
This article continues a series of articles on the constructive ownership rules of the IRC (Internal Revenue Code) §318. Today, we will discuss corporate attribution rules, even more specifically the §318 downstream corporate attribution rules. §318 Downstream Corporate Attribution: Two Types of Attribution There are two types of §318 corporate attribution rules: downstream and upstream. […]
Beginning January 1, 2020, the IRS changed the optional standard mileage for the calculation of deductible costs of operating an automobile (sedans, vans, pickups and panel trucks) for business, charitable, medical or moving purposes. Let’s discuss in more detail these new 2020 IRS Standard Mileage Rates. 2020 IRS Standard Mileage Rates for Business Usage For […]
For some years now, India has remained at the top of all countries that receive remittances in US dollars. A lot of these funds flow from Indian-Americans and Indians who reside in the United States. The problem is that a lot of them are not in compliance with respect to their US international tax obligations […]
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In a previous article, I explained special §318 rules concerning grantor trusts as an exception to the general §318 trust attribution rules. Today, I will discuss the special §318 employee trust attribution rules as another exception to the general §318 trust attribution rules. §318 Employee Trust Attribution: Focus on Tax-Exempt Employee Trusts First of all, […]
In previous articles, I discussed the §318 downstream and upstream attribution rules; in that context, I also mentioned that there were special rules concerning grantor trusts and tax-exempt employee trusts. This article will cover the special §318 grantor trust attribution rules. §318 Grantor Trust Attribution: Definition of Grantor Trust A grantor trust is any trust […]
In a previous article, I discussed the Internal Revenue Code (“IRC”) §318 downstream trust attribution rules. Today, I would like to focus on the §318 upstream trust attribution rules. §318 Upstream Trust Attribution: Downstream vs. Upstream There are two types of §318 trust attribution: downstream and upstream. In a previous article, I already covered the […]
In this article, I would like to introduce the readers to the concept of US information returns; I will also explore the differences between US information returns and US tax returns. US Information Returns: Two Types of Returns The US tax system is a self-assessment system where taxpayers must file certain forms or returns developed […]
Many taxpayers and even tax professionals are completely unaware of the fact that FBAR needs to be filed not just by individuals, businesses and trusts, but also by estates. In this article, I will discuss FinCEN Form 114 Estate filers (i.e. estates that need to file FinCEN Form 114). FinCEN Form 114 Estate filers: FBAR […]
The attribution of stock ownership to constructive owners is a highly important feature of US domestic and international tax law. The Internal Revenue Code (“IRC”) §318 contains complex constructive ownership rules concerning corporate stock; these rules vary depending on a specific §318 relationship. This article focuses on an important category of §318 relationships – trusts. […]
This article continues a series of articles concerning the constructive ownership rules of the Internal Revenue Code (“IRC”) §318. Today’s focus is on the §318 upstream estate attribution rules. §318 Estate Attribution Rules: Downstream Attribution vs. Upstream Attribution There are two types of the IRC §318 estate attribution rules: downstream and upstream. In a previous […]
The Internal Revenue Code (“IRC”) §318 contains corporate stock attribution rules between an estate and its beneficiaries. In order to apply these rules correctly, one must understand how §318 defines “beneficiary” for the purposes of upstream and downstream estate attribution rules. This articles will introduce the readers to this §318 estate beneficiary definition. §318 Estate […]
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This article continues a series of articles on the Internal Revenue Code (“IRC”) §318 constructive ownership rules. Today, the topic is §318 estate attribution rules – i.e. attribution of ownership of corporate stock from estate to its beneficiaries and vice versa. Since this is a long topic, I will divide it into three articles. This […]
In a recent article, I mentioned that Streamlined Domestic Offshore Procedures (“SDOP”) will continue to be the most important voluntary disclosure option in 2020 for US taxpayers who reside in the United States. However, not all taxpayers will qualify to participate in the 2020 SDOP. In this article, I will discuss the main 2020 SDOP […]
This article continues a series of articles on the Internal Revenue Code (“IRC”) §318 constructive ownership rules. In this essay, we will discuss the §318 partnership attribution rules – i.e. attribution of ownership of shares from partnership to partners and vice versa. §318 Partnership Attribution Rules: Two Types There are two types of the IRC […]
On November 18, 2019, the Ukrainian FATCA IGA entered into force. Sherayzen Law Office already wrote on this subject a little more than three years ago. This essay updates the status of the Ukrainian FATCA IGA. Ukrainian FATCA IGA: Background Information The Foreign Account Tax Compliance Act (FATCA) was enacted into law in 2010 and […]
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The 2019 FBAR conversion rates are highly important in US international tax compliance. The 2019 FBAR and 2019 Form 8938 instructions both require that 2019 FBAR conversion rates be used to report the required highest balances of foreign financial assets on these forms (in the case of Form 8938, the 2019 FBAR conversion rates is […]
Noncompliant US taxpayers with undisclosed foreign assets and foreign income should consider their voluntary disclosure options in this new year 2020. Similarly to 2019, I expect that this year Streamlined Domestic Offshore Procedures will continue to be the flagship voluntary disclosure option for such taxpayers who reside in the United States. In order for the […]
In a previous article, I outlined six main relationship categories of the Internal Revenue Code (“IRC”) §318. In this article, I will focus on the first of these categories: the IRC §318 family attribution rules. §318 Family Attribution: General Rule §318(a)(1)(A) describes the §318 family attribution rule . It states that an individual is a […]
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As the new year 2020 begins, it is important for US taxpayers with undisclosed foreign assets to consider their 2020 offshore voluntary disclosure options. Unlike last year, there have not been any drastic changes to the voluntary disclosure options since 2019. In this article, I would like to generally explore the 2020 offshore voluntary disclosure […]
On January 6, 2020, the IRS announced that the 2019 tax filing season will commence on Monday, January 27, 2020. In other words, on that date, the IRS will begin accepting and processing the 2019 tax returns. This year the deadline for the filing of the 2019 tax returns as well as any payment of […]
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In a series of articles concerning Internal Revenue Code (“IRC”) §267, I discussed various rules concerning related party loss disallowance. In this article, I would like to focus on special rules concerning partnership related party loss disallowance. Partnership Related Party Loss Disallowance: Main IRC Provisions Three IRC sections are most relevant to special rules of […]
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In a previous article I discussed the importance of the Internal Revenue Code (“IRC”) §318 constructive stock ownership rules. Today, I would like to introduce the readers to the various §318 relationship categories – i.e. what types of taxpayers are affected by this section’s constructive ownership rules. §318 Relationship Categories: Related Persons Congress created IRC […]
It is difficult to overstate the significant role the Internal Revenue Code (“IRC”) §318 plays in US corporate tax law and US international tax law. In this article, I will explain the §318 importance and list out major IRC provisions which reference §318. IRC §318 Importance: Fundamental Purpose §318 sets forth the circumstances when the […]
The IRS stated in December of 2019 that it hired about 9,500 people during the fiscal year 2019 and it is trying to add another about 5,300 employees as soon as possible. This new IRS hiring spree is meant to reverse the long-term declining trend in IRS employment. The IRS Hiring Spree: 2009-2018 Trend Between […]
In a previous article, I introduced the constructive ownership rules of the Internal Revenue Code (“IRC”) §267. Today, I would like to discuss one of them in more detail – §267 family attribution. §267 Family Attribution: General Rule The §267 family attribution rule is described in §267(c)(2). It states that, for the purposes of determining […]
In a previous article, I introduced the Internal Revenue Code (“IRC”) §267 constructive ownership rules. Today, I would like to focus specifically on the §267 entity-to-member attribution rule. §267 Entity-to-Member Attribution: General Rule §267(c)(1) describes the §267 entity-to-member attribution rule. It states that stocks owned by a corporation, partnership, estate or trust will be treated […]
In a previous article, I discussed the related person definition for the purposes of the Internal Revenue Code (“IRC”) §267. That article, however, focused on the definition itself rather than on a host of supplementary rules necessary to fully understand this definition. In this article, I would like to discuss one set of these rules […]
Internal Revenue Code (“IRC”) §267 imposes significant restrictions on the ability of related persons to recognize loss from a transaction that involves a sale or exchange of property. Hence, it is important for a tax attorney who advises on such a transaction to understand the concept of a “related person” in order to properly advise […]
Sherayzen Law Office wishes everyone a very happy and prosperous New Year 2020! We also wish you stay in full US tax compliance with US international tax laws while your tax burden decreases! And, we are here to help our clients to turn these wishes into reality! In the year 2020, Sherayzen Law Office will […]
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This brief essay explores the IRC §267 purpose of existence – i.e. Why did Congress decide to enact IRC §267 and in what situations does it generally apply? IRC §267 Purpose: Problematic Scenarios When Congress enacted IRC §267, it meant to address a very specific problem in the context of two scenarios. The problem was […]
One of the most popular tax reduction strategies is based on shifting an ownership interest in an entity or property to related persons or related entities. In order to prevent the abuse of this strategy, the US Congress has enacted a large number of attribution rules. In this brief essay, I will introduce the concept […]
On December 6, 2019, the Internal Revenue Service (“IRS”) announced that the 2020 First Quarter IRS underpayment and overpayment interest rates will not change from the 4th Quarter of 2019. This means that, the 2020 First Quarter IRS underpayment and overpayment interest rates will be as follows: Under the Internal Revenue Code, the rate of […]
A significant number of US taxpayers who went through the OVDP mistakenly believed that they were immune from the IRS post-OVDP audits concerning their post-voluntary disclosure compliance. Sherayzen Law Office has repeatedly warned in the past that these taxpayers were mistaken with respect to their exposure to potential post-OVDP audits. The recent announcement of a […]
On November 8, 2019, the Federal Circuit Court of Appeals (the “Court”) upheld the decision of the Court of Federal Claims to uphold the IRS assessment of a willful FBAR penalty in the amount of $803,530 with respect to Ms. Mindy Norman’s failure to file her 2007 FBAR. The Norman case deserves special attention because […]
On November 19, 2019, the IRS announced changes to the current FBAR filing verification submission process. The change is technical, but not without importance.
On November 21, 2019, Mr. Eugene Sherayzen, an international tax attorney and founder of Sherayzen Law Office, Ltd., conducted a seminar at the Belarusian State University Law School (the “2019 BSU Seminar”) in Minsk, Belarus. Let’s explore the 2019 BSU Seminar in more detail. 2019 BSU Seminar: Topic and Attendance The topic of the seminar […]
The new Greek government headed by Prime Minister Kyriakos Mitsotakis wishes to reach 2.8% economic growth next year. Part of the plan to achieve this goal includes a tax reform which introduces a curious new concept of Greek flat tax residency for wealthy foreign investors. Let’s discuss this interesting idea in more detail. Greek Flat […]
There is a surprisingly large number of US taxpayers who believe that reporting foreign income that was not disclosed on a Form W-2 or 1099 is unnecessary. Even if they honestly believe it to be true, this erroneous belief exposes these taxpayers to an elevated risk of imposition of high IRS penalties. In this article, […]
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On September 6, 2019, the Tax Division of the US Department of Justice (“DOJ”) announced another victory against Offshore Tax Evasion. This time, a Houston lawyer, Mr. Jack Stephen Pursley, was convicted of one count of conspiracy to defraud the United States and three counts of tax evasion. Let’s discuss this Pursley Case in more […]
On August 27, 2019, the US Department of Justice (“DOJ”) announced that a federal grand jury returned a superseding indictment charging Mr. Brian Booker, a former resident of Fort Lauderdale, Florida, whose business specialized in international trade, with failing to file Reports of Foreign Bank and Financial Accounts (“FBARs”) and filing false documents with the […]
On July 19, 2019, the IRS Large Business and International division (LB&I) announced the approval of another six compliance campaigns. Let’s discuss in more detail these July 2019 IRS compliance campaigns. July 2019 IRS Compliance Campaigns: Background Information In the mid-2010s, after extensive tax planning, the IRS decided to restructure LB&I in a way that […]
I often receive questions concerning a child’s FBAR requirements. Many taxpayers automatically assume that, if their children are below the age of majority, these children do not have to file FBARs. Unfortunately, this is not the case – a child’s FBAR requirements are every bit as extensive of those of his parents. Child’s FBAR Requirements: […]
On August 28, 2019, the Internal Revenue Service (“IRS”) announced that the 2019 Fourth Quarter IRS underpayment and overpayment interest rates will not change from the 3rd Quarter of 2019. This means that, the 2019 Fourth Quarter IRS underpayment and overpayment interest rates will be as follows: Under the Internal Revenue Code, the rate of […]
On October 15, 2019, Sherayzen Law Office, Ltd., successfully completed its 2019 Fall Tax Season. It was a challenging and interesting tax season. Let’s discuss it in more detail. 2019 Fall Tax Season: Sherayzen Law Office’s Annual Compliance Clients Annual tax compliance is one of the major services offered by Sherayzen Law Office to its […]
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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 […]
In this article, I would like to discuss the legal definition of Responsible Person under Minn. Stat. § 270C.56 – I will refer to this term as Minnesota sales tax responsible person legal standard. Minnesota Sales Tax Responsible Person: Background Information Minnesota imposes a sales tax “on the gross receipts from retail sales.” Minn. Stat. […]
In July of 2019, Mr. Eugene Sherayzen, an international tax attorney and owner of Sherayzen Law Office, Ltd., completed his business trip to Zurich, Switzerland. Let’s discuss in more detail this 2019 Zurich Trip, its goals and accomplishments. 2019 Zurich Trip: Goals Mr. Sherayzen outlined the firm’s goals for the Zurich trip during the Sherayzen […]
Mr. Eugene Sherayzen, an international tax attorney and owner of Sherayzen Law Office, Ltd., completed his trip to Karlovy Vary, Czech Republic, on July 10, 2019. Let’s discuss in more detail this brief 2019 Karlovy Vary trip, its motivations and results. 2019 Karlovy Vary Trip: Reasons for this Excursion There were several reasons why Mr. […]
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The Legal Entity Identifiers (“LEI”) is a method to identify legal entities that engage in financial transactions. Let’s discuss LEI in more detail. LEI: Background Information The establishment of LEI was driven by the recognition by regulators around the world that there is a complete lack of transparency with respect to identifying parties to international […]
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In May of 2019, Mr. Andrew Keyso, a deputy chief of the IRS Office of Appeals, stated that the Appeals Office is in the early stages of rolling out the technology to conduct video conferences as an option for Appeals conferences. This is great news for tax practitioners – an IRS Appeals video conference is […]
On May 1, 2019, the United States District Court for the Western District of North Carolina (the “Court”) authorized the IRS to serve John Doe Summonses seeking information about Finnish residents who own secret US bank accounts (collectively Finnish US Bank Accounts). Let’s discuss this development concerning Finnish US bank accounts in more depth. Finnish […]
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The IRS Private Letter Rulings (“PLR”) and the IRS Technical Advice Memoranda (“TAM”) often get confused by non-practitioners. In this small essay, I will engage in a brief PLR TAM comparison in order to clarify the similarities and differences between both types of IRS administrative guidance. PLR TAM Comparison: Similarities Let’s begin our PLR TAM […]
On April 4, 2019, the IRS issued the FBAR Fact Sheet in order to acquaint US taxpayers with this highly important reporting requirement for foreign accounts held by US persons. Let’s analyze the new fact sheet in more detail. FBAR Fact Sheet: Organizational Structure of the Fact Sheet The IRS FBAR Fact Sheet can be […]
An analysis of the fiscal year 2018 DOJ criminal case statistics reveals certain interesting patterns about federal criminal tax prosecution in that year. Let’s explore in more detail these patterns. 2018 DOJ Criminal Case Statistics: Typical Tax Criminal The analysis of the FY 2018 DOJ criminal case statistics reveals an interesting fact – a typical […]
On June 7, 2019, the Organization for Economic Cooperation and Development (“OECD”) announced that countries shared information concerning 47 million financial accounts under the OECD’s Common Reporting Standard (“CRS”). Let’s explore this CRS success in more detail. Measuring CRS Success: What is CRS? CRS can be called the response of the rest of the world […]
US taxpayers who own Hungarian bank accounts may have to comply with a large number of US tax reporting requirements. In particular, they need to be concerned about reporting income generated by their Hungarian bank accounts as well as disclosing the ownership of these accounts on FBAR and Form 8938. Other requirements may apply, but […]
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On June 5, 2019, the Internal Revenue Service announced 2019 Third Quarter IRS Interest Rates. This quarter, the IRS interest rates will be reduced for the first time in years. 2019 Third Quarter IRS Interest Rates: 3rd Quarter and Interest Rates Defined Third quarter of 2019 begins on July 1, 2019 and ends on September […]
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On May 31, 2019, the IRS released a Private Letter Ruling (“PLR”) on the extension of time to make an election to be treated as a disregarded entity for US tax purposes under Treas. Reg. Section 301.7701 (26 CFR 301.7701-3). Let’s explore this PLR 201922010 in more detail. PLR 201922010: Fact Pattern PLR 201922010 deals […]
The 2017 Tax Reform created the Internal Revenue Code Section 965, which requires US shareholders of foreign corporations to pay a new transition tax (hereinafter, “IRC 965 Tax”) in certain circumstances. In this short article, I will introduce the readers to the IRC 965 Tax. IRC 965 Tax: Taxpayers Who Are Targeted by the New […]
On April 16, 2019, the IRS Large Business and International division (LB&I) announced the approval of three additional compliance campaigns. Let’s discuss in more detail these April 2019 IRS compliance campaigns. April 2019 IRS Compliance Campaigns: Background Information In the mid-2010s, after extensive planning, the IRS decided to move LB&I toward issue-based examinations and a […]
On May 15, 2019, a Texas federal court ruled that the IRS can enforce a John Doe Summons for client information from Taylor Lohmeyer Law Firm because the firm failed to demonstrate that the attorney-client privilege protected this information. This is bad news for Taylor Lohmeyer Law Firm clients who now may have to face […]
A large number of US taxpayers own Panamanian bank accounts. These taxpayers have bank accounts in Panama for a variety of reasons: personal, business, tax planning and/or estate planning. Many of these account holders still do not realize that their Panamanian bank accounts may be subject to numerous reporting requirements in the United States. In […]
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Orlando Foreign Trust Attorney | International Tax Lawyers Florida
/in foreign trust lawyer, Legal Notes /by ManagerIf you live in Orlando, Florida, and you are an owner or a beneficiary of a foreign trust, you need to secure the help of a Orlando Foreign Trust Attorney to properly comply with US international tax laws. You should consider retaining Sherayzen Law Office as your Orlando Foreign Trust Attorney. Sherayzen Law Office is […]
Miami Foreign Trust Attorney | International Tax Lawyers Florida
/in foreign trust lawyer, Legal Notes /by ManagerIf you live in Miami, Florida, and you are an owner or a beneficiary of a foreign trust, you need to secure the help of a Miami Foreign Trust Attorney to properly comply with US international tax laws. You should consider retaining Sherayzen Law Office as your Miami Foreign Trust Attorney. Sherayzen Law Office is […]
Athens FBAR Attorney | International Tax Lawyer Georgia
/in FBAR Lawyers, Legal Notes /by ManagerIf you reside in Athens, Georgia and have unreported foreign bank and financial accounts, you may be looking for a Athens 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. Athens FBAR Attorney: International […]
Fourth Quarter 2024 IRS Interest Rates on Overpayment & Underpayment of Tax
/in irs lawyer minneapolis, Legal Notes /by ManagerOn August 21, 2024, the IRS announced that the Fourth Quarter 2024 IRS interest rates on overpayment and underpayment of tax will remain the same as in the Third Quarter of 2024. This means that, the Fourth Quarter 2024 IRS interest rates will be as follows: eight (8) percent for overpayments (seven (7) percent in the case of a corporation); eight (8) percent for underpayments; […]
Atlanta Foreign Trust Attorney | International Tax Lawyers Georgia
/in foreign trust lawyer, Legal Notes /by ManagerIf you live in Atlanta, Georgia, and you are an owner or a beneficiary of a foreign trust, you need to secure the help of a Atlanta Foreign Trust Attorney to properly comply with US international tax laws. You should consider retaining Sherayzen Law Office as your Atlanta Foreign Trust Attorney. Sherayzen Law Office is […]
San Antonio FBAR Tax Attorney | International Tax Lawyer Texas
/in FBAR Lawyers, Legal Notes /by ManagerIf you reside in San Antonio, Texas, and have unreported foreign bank and financial accounts, you may be looking for a San Antonio FBAR Tax 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. […]
Start-Up Year PFIC Exception | International Tax Lawyer & Attorney
/in Legal Notes, PFIC tax lawyer /by ManagerPassive Foreign Investment Company (PFIC) classification of a foreign corporation may have highly undesirable consequences for its US shareholders. In addition to high PFIC tax, these taxpayers face expensive and burdensome tax reporting requirements. This is why US taxpayers and their tax advisers generally try to avoid PFIC designation. This article explores a possible way […]
FBAR Financial Accounts Definition | International Tax Lawyer & Attorney
/in FBAR Lawyers, FBAR lawyers New York, Legal Notes /by ManagerIn the realm of US international tax compliance, few topics are as crucial as the reporting of foreign financial accounts, particularly The Foreign Bank and Financial Accounts Report (FBAR). This article focuses on one specific aspect of FBAR compliance: what accounts need to be disclosed on FBAR. In particular, we will delve into the intricacies of […]
Knoxville FBAR Attorney | International Tax Lawyer Tennessee
/in FBAR Lawyers, Legal Notes /by ManagerIf you reside in Knoxville, Tennessee and have unreported foreign bank and financial accounts, you may be looking for a Knoxville 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. Knoxville FBAR Attorney: International […]
Fort Collins FBAR Tax Attorney | International Tax Lawyer Colorado
/in FBAR Lawyers, Legal Notes /by ManagerIf you reside in Fort Collins, Colorado, and have unreported foreign bank and financial accounts, you may be looking for a Fort Collins FBAR Tax 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. […]
Chattanooga FBAR Attorney | International Tax Lawyer Tennessee
/in FBAR Lawyers, Legal Notes /by ManagerIf you reside in Chattanooga , Tennessee and have unreported foreign bank and financial accounts, you may be looking for a Chattanooga 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. Chattanooga […]
Nashville FBAR Attorney | International Tax Lawyer Tennessee
/in FBAR Lawyers, Legal Notes /by ManagerIf you reside in Nashville, Tennessee and have unreported foreign bank and financial accounts, you may be looking for a Nashville 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. Nashville FBAR Attorney: International […]
Colorado Springs FBAR Tax Attorney | International Tax Lawyer Colorado
/in FBAR Lawyers, Legal Notes /by ManagerIf you reside in Colorado Springs, Colorado, and have unreported foreign bank and financial accounts, you may be looking for a Colorado Springs FBAR Tax 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. […]
Corpus Christi Foreign Inheritance Lawyer | International Tax Attorney Texas
/in foreign inheritance, International Tax Attorney, Legal Notes /by ManagerRetaining a Corpus Christi foreign inheritance lawyer to deal with the IRS is very likely to be necessary if you reside in Corpus Christi, Texas and have received an inheritance from a non-resident alien (i.e. foreign inheritance). Sherayzen Law Office, Ltd. is a leader in US international tax compliance concerning foreign inheritance, including offshore voluntary disclosures concerning late disclosure of a foreign […]
Glenview FBAR Attorney | International Tax Lawyer Kentucky
/in FBAR Lawyers, Legal Notes /by ManagerIf you reside in Glenview, Kentucky and have unreported foreign bank and financial accounts, you may be looking for a Glenview 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. Glenview FBAR Attorney: International […]
Closer Connection Exception | International Tax Lawyer & Attorney
/in International Tax Attorney Minnesota Minneapolis, international tax lawyer, Legal Notes /by ManagerThe Closer Connection Exception is a very important provision in US international tax law, because it provides a potential way for individuals who meet the Substantial Presence Test to still be treated as nonresident aliens for US income tax purposes. This article explores the Closer Connection Exception, its requirements and its implications for US and foreign taxpayers. Understanding the Closer […]
Louisville FBAR Attorney | International Tax Lawyer Kentucky
/in FBAR Lawyers, Legal Notes /by ManagerIf you reside in Louisville, Kentucky and have unreported foreign bank and financial accounts, you may be looking for a Louisville 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. Louisville FBAR Attorney: International […]
Substantial Presence Test | US International Tax Lawyer & Attorney
/in international tax lawyer, Lead Article /by ManagerThe substantial presence test is one of the most important legal tests in the Internal Revenue Code (IRC), because it determines whether a person is a US tax resident solely by virtue of his physical presence in the United States. Additionally, this Test is essential to the determination of whether a person is a “US […]
Digital Currency Final Regulations: Broad Overview | Cryptocurrency Tax Attorney
/in cryto tax lawyer, Legal Notes /by ManagerOn June 28, 2024, the U.S. Department of the Treasury and the Internal Revenue Service (IRS) have issued final regulations requiring brokers to report sales and exchanges of digital assets, including cryptocurrency. These digital currency final regulations aim to improve tax compliance and provide taxpayers with necessary information for accurate tax reporting. Digital Currency Final […]
Indianapolis FBAR Attorney | International Tax Lawyer Indiana
/in FBAR Lawyers, Legal Notes /by ManagerIf you reside in Indianapolis, Indiana and have unreported foreign bank and financial accounts, you may be looking for a Indianapolis 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. Indianapolis FBAR Attorney: International […]
Waco Foreign Inheritance Lawyer | International Tax Attorney Texas
/in foreign inheritance, International Tax Attorney, Legal Notes /by ManagerRetaining a Waco foreign inheritance lawyer to deal with the IRS is very likely to be necessary if you reside in Waco, Texas and have received an inheritance from a non-resident alien (i.e. foreign inheritance). Sherayzen Law Office, Ltd. is a leader in US international tax compliance concerning foreign inheritance, including offshore voluntary disclosures concerning late disclosure of a foreign inheritance, and […]
Abilene Foreign Inheritance Lawyer | International Tax Attorney Texas
/in foreign inheritance, Legal Notes /by ManagerRetaining a Abilene foreign inheritance lawyer to deal with the IRS is very likely to be necessary if you reside in Abilene, Texas and have received an inheritance from a non-resident alien (i.e. foreign inheritance). Sherayzen Law Office, Ltd. is a leader in US international tax compliance concerning foreign inheritance, including offshore voluntary disclosures concerning late disclosure of a foreign inheritance, and […]
Boulder FBAR Tax Attorney | International Tax Lawyer Colorado
/in FBAR Lawyers, Legal Notes /by ManagerIf you reside in Boulder, Colorado, and have unreported foreign bank and financial accounts, you may be looking for a Boulder FBAR Tax 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. Boulder […]
PFIC Compliance: Introduction | International Tax Lawyer & Attorney
/in Legal Notes, PFIC tax lawyer /by ManagerIn the intricate realm of US international tax law, few areas are as challenging and potentially costly as PFIC compliance. Understanding the nuances of Passive Foreign Investment Companies (PFICs) is crucial for US taxpayers with foreign investments. This article provides an introduction to PFIC compliance, outlining key concepts and reporting requirements. What is PFIC Compliance? […]
McKinney Foreign Inheritance Lawyer | International Tax Attorney Texas
/in foreign inheritance, Legal Notes /by ManagerRetaining a McKinney foreign inheritance lawyer to deal with the IRS is very likely to be necessary if you reside in McKinney, Texas and have received an inheritance from a non-resident alien (i.e. foreign inheritance). Sherayzen Law Office, Ltd. is a leader in US international tax compliance concerning foreign inheritance, including offshore voluntary disclosures concerning late disclosure of a foreign inheritance, and […]
Dallas Foreign Inheritance Lawyer | International Tax Attorney Texas
/in foreign inheritance, Legal Notes /by ManagerRetaining a Dallas foreign inheritance lawyer to deal with the IRS is very likely to be necessary if you reside in Dallas, Texas and have received an inheritance from a non-resident alien (i.e. foreign inheritance). Sherayzen Law Office, Ltd. is a leader in US international tax compliance concerning foreign inheritance, including offshore voluntary disclosures concerning late disclosure of a foreign inheritance, and […]
2024 Form 8938 Threshold | US International Tax Lawyers
/in Legal Notes /by ManagerUS taxpayers must file Form 8938 with their US tax returns if they hold foreign financial assets with an aggregate value exceeding a relevant balance threshold. This article discusses the 2024 Form 8938 threshold limits. 2024 Form 8938 Threshold: Form 8938 Background Form 8938 burst onto the US international compliance scene in 2011 as a result […]
Austin Foreign Inheritance Lawyer | International Tax Attorney Texas
/in foreign inheritance, international tax lawyer, Legal Notes /by ManagerRetaining a Austin foreign inheritance lawyer to deal with the IRS is very likely to be necessary if you reside in Austin, Texas and have received an inheritance from a non-resident alien (i.e. foreign inheritance). Sherayzen Law Office, Ltd. is a leader in US international tax compliance concerning foreign inheritance, including offshore voluntary disclosures concerning late disclosure of a foreign inheritance, and […]
Houston Foreign Inheritance Lawyer | International Tax Attorney Texas
/in foreign inheritance, International Tax Attorney, Legal Notes /by ManagerRetaining a Houston foreign inheritance lawyer to deal with the IRS is very likely to be necessary if you reside in Houston, Texas and have received an inheritance from a non-resident alien (i.e. foreign inheritance). Sherayzen Law Office, Ltd. is a leader in US international tax compliance concerning foreign inheritance, including offshore voluntary disclosures concerning late disclosure of a foreign inheritance, and […]
Minneapolis Foreign Inheritance Lawyer | International Tax Attorney Minnesota
/in foreign inheritance, International Tax Attorney Minnesota Minneapolis, Legal Notes /by ManagerRetaining a Minneapolis foreign inheritance lawyer to deal with the IRS is very likely to be necessary if you reside in Minneapolis, Minnesota and have received an inheritance from a non-resident alien (i.e. foreign inheritance). Sherayzen Law Office, Ltd. is a leader in US international tax compliance concerning foreign inheritance, including offshore voluntary disclosures concerning late […]
Milwaukee FBAR Attorney | International Tax Lawyer Wisconsin
/in FBAR Lawyers, Legal Notes /by ManagerIf you reside in Milwaukee, Wisconsin and have unreported foreign bank and financial accounts, you may be looking for a Milwaukee 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. Milwaukee FBAR Attorney: International […]
2024 FBAR Civil Penalties | FBAR International Tax Lawyer & Attorney
/in FBAR Lawyers, Legal Notes /by ManagerThis article is an update of prior articles on the FBAR Civil Penalties. Since the US Congress mandated the IRS to adjust FBAR civil penalties for inflation on an annual basis, this article discusses the year 2024 FBAR Civil Penalties. 2024 FBAR Civil Penalties: Overview of the FBAR Penalty System FinCEN Form 114, the Report of Foreign Bank and […]
Denver FBAR Tax Attorney | International Tax Lawyer Colorado
/in FBAR Lawyers, Legal Notes /by ManagerIf you reside in Denver, Colorado, and have unreported foreign bank and financial accounts, you may be looking for a Denver FBAR Tax 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. Denver […]
Third Quarter 2024 IRS Interest Rates on Overpayment & Underpayment of Tax
/in Legal Notes, Tax Lawyers Minneapolis /by ManagerOn May 9, 2024, the IRS announced that the Third Quarter 2024 IRS interest rates on overpayment and underpayment of tax will remain the same as in the Second Quarter of 2024. This means that, the Third Quarter 2024 IRS interest rates will be as follows: Internal Revenue Code (“IRC”) §6621 establishes the IRS interest rates on overpayments and underpayments of tax. Under §6621(a)(1), the […]
High Income Non-Filer IRS Compliance Campaign Update: Notice CP-59 With International Tax Compliance Focus
/in IRS Audit Lawyers, Legal Notes /by ManagerOn February 29, 2024, the IRS announced a major update to one of its compliance campaigns that focuses on high income non-filer taxpayers. Let’s discuss this major update to the High Income Non-filer IRS Campaign in more detail. High Income Non-Filer IRS Campaign: Background Information As part of its extensive tax enforcement planning in the […]
Garland FBAR Attorney | International Tax Lawyer Texas
/in FBAR Lawyers, Legal Notes /by ManagerIf you reside in Garland, Texas and have unreported foreign bank and financial accounts, you may be looking for a Garland FBAR Attorney. Sherayzen Law Office, Ltd. is a leader in FBAR compliance, including offshore voluntary disclosures concerning delinquent FBARs, consider us in your search. Let’s understand why this is the case. Garland FBAR Attorney: International Tax Lawyer First of […]
McKinney Foreign Trust Attorney | International Tax Lawyers Texas
/in foreign trust lawyer, Legal Notes /by ManagerIf you live in McKinney, Texas, and you are an owner or a beneficiary of a foreign trust, you need to secure the help of a McKinney Foreign Trust Attorney to properly comply with US international tax laws. You should consider retaining Sherayzen Law Office as your McKinney Foreign Trust Attorney. Sherayzen Law Office is […]
IRS Corporate Jet Audits Campaign | MN IRS Audit Tax Lawyer
/in international tax lawyer, IRS Audit Lawyers, Legal Notes /by ManagerOn February 21, 2024, the IRS announced that it will begin dozens of audits of business aircraft usage as part of a new tax enforcement campaign. In this short article, I will discuss these new IRS corporate jet audits in more detail. IRS Corporate Jet Audits: Focus on Personal Use of High-Net Individuals The IRS […]
Second Quarter 2024 IRS Interest Rates on Overpayment & Underpayment of Tax
/in IRS Lawyers, Legal Notes /by ManagerOn February 21, 2024, the IRS announced that the Second Quarter 2024 IRS interest rates on overpayment and underpayment of tax will remain the same as in the First Quarter of 2024. This means that, the Second Quarter 2024 IRS interest rates will be as follows: Internal Revenue Code (“IRC”) §6621 establishes the IRS interest rates on overpayments and underpayments of tax. Under §6621(a)(1), the overpayment […]
McKinney FBAR Attorney | International Tax Lawyer Texas
/in FBAR Lawyers, Legal Notes /by ManagerIf you reside in McKinney, Texas and have unreported foreign bank and financial accounts, you may be looking for a McKinney 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. McKinney FBAR Attorney: International […]
Dallas Foreign Trust Attorney | International Tax Lawyers Texas
/in foreign trust lawyer, Legal Notes /by ManagerIf you live in Dallas, Texas, and you are an owner or a beneficiary of a foreign trust, you need to secure the help of a Dallas Foreign Trust Attorney to properly comply with US international tax laws. You should consider retaining Sherayzen Law Office as your Dallas Foreign Trust Attorney. Sherayzen Law Office is […]
San Jose FBAR Attorney | International Tax Lawyer California
/in FBAR Lawyers, Legal Notes /by ManagerIf you reside in San Jose, California and have unreported foreign bank and financial accounts, you may be looking for a San Jose 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. San […]
Midland FBAR Attorney | International Tax Lawyer Texas
/in FBAR Lawyers, Legal Notes /by ManagerIf you reside in Midland, Texas and have unreported foreign bank and financial accounts, you may be looking for a Midland 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. Midland FBAR Attorney: International […]
TAS Significant Hardship Definition | International Tax Lawyer & Attorney
/in IRS Audit Lawyers, Legal Notes /by ManagerSometimes, a taxpayer may find himself in a situation where his problem cannot be resolved through normal IRS channels. In this case, one of the options is to secure the help of the Taxpayer Advocate Service (“TAS”). TAS can issue a Taxpayer Assistance Order (TAO) to require the IRS to desist from a certain action […]
Big Spring FBAR Attorney | International Tax Lawyer Texas
/in FBAR Lawyers, Legal Notes /by ManagerIf you reside in Big Spring, Texas and have unreported foreign bank and financial accounts, you may be looking for a Big Spring 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. Big […]
Offshore Voluntary Disclosure: Client Records | International Tax Lawyer
/in FBAR Lawyers, International Tax Attorney, Legal Notes /by ManagerOne of the first things a client must get in order to pursue an offshore voluntary disclosure are all of the client records from his former accountant. Sometimes, however, the clients are having difficulty obtaining their documents from their accountants. In this article, I would like to briefly describe an accountant’s obligations with respect to […]
Reasonable Cause Written Advice Standard | International Tax Lawyer
/in International Tax Attorney, Legal Notes /by ManagerReliance 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
/in Legal Notes, offshore voluntary disclosure lawyers Minneapolis /by ManagerOn 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
/in Legal Notes, Streamlined Domestic Offshore Procedures /by ManagerMinnesota 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
/in FBAR Lawyers, Legal Notes /by ManagerIf 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 […]
Abilene Foreign Trust Attorney | International Tax Lawyers Texas
/in foreign trust lawyer, Legal Notes /by ManagerIf you live in Abilene, Texas, and you are an owner or a beneficiary of a foreign trust, you need to secure the help of a Abilene Foreign Trust Attorney to properly comply with US international tax laws. You should consider retaining Sherayzen Law Office as your Abilene Foreign Trust Attorney. Sherayzen Law Office is […]
Corpus Christi FBAR Attorney | International Tax Lawyer Texas
/in FBAR Lawyers, Legal Notes /by ManagerIf you reside in Corpus Christi, Texas and have unreported foreign bank and financial accounts, you may be looking for a Corpus Christi 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. Corpus […]
IRS Limited Practice Exceptions | Tax Lawyer St Paul Minnesota
/in Legal Notes, tax lawyer St. Paul Minnesota /by ManagerGenerally, only attorneys, CPAs, enrolled agents and enrolled actuaries can act as taxpayer representatives before the IRS. However, Circular 230 §10.7 contains several limited exceptions to this general requirement. Let’s explore these IRS limited practice exceptions. IRS Limited Practice Exceptions: Standard of Conduct Before we discuss the exceptions, I would like to point out that […]
Internal Revenue Manual: Introduction | IRS Audit Lawyer St Paul
/in IRS Audit Lawyers, Legal Notes /by ManagerInternal Revenue Manual: Description & Purpose Internal Revenue Manual (“IRM”) is the primary, official source of IRS instructions to staff that relate to the administration and operation of the IRS. The rules set in the IRM are meant to provide guidance to the IRS employees (including managers) in their daily work life. The IRM is […]
Abilene FBAR Attorney | International Tax Lawyer Texas
/in FBAR Lawyers, Legal Notes /by ManagerIf you reside in Abilene, Texas and have unreported foreign bank and financial accounts, you may be looking for a Abilene 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. Abilene FBAR Attorney: International […]
Florida Streamlined Disclosure Attorney | International Tax Lawyer
/in Legal Notes, Streamlined Domestic Offshore Procedures, Streamlined Foreign Offshore Procedures /by ManagerFlorida has a huge immigrant community with over 21% of the population foreign-born and another more than 12% of the population that has at least one immigrant parent. The top countries of original for immigrants are: Cuba, Haiti, Colombia, Mexico and Jamaica. Many of these new US taxpayers own assets in foreign countries and receive income generated by […]
Waco Foreign Trust Attorney | International Tax Lawyer Texas
/in foreign trust lawyer, Legal Notes /by ManagerIf you live in Waco, Texas, and you are an owner or a beneficiary of a foreign trust, you need to secure the help of a Waco Foreign Trust Attorney to properly comply with US international tax laws. You should consider retaining Sherayzen Law Office as your Waco Foreign Trust Attorney. Sherayzen Law Office is […]
Special October 7 FBAR Deadline for 2022 FBAR | International Tax Lawyer
/in FBAR Lawyers, Legal Notes /by ManagerIn this calender year 2024, there is a special October 7 FBAR deadline that was created by FinCEN in response to the October 7 terrorist attack against Israel. Let’s discuss discuss this special October 7 FBAR deadline in more detail. October 7 FBAR Deadline: Background Information The terrorist attack on Israel on October 7, 2023 […]
Waco FBAR Attorney | International Tax Lawyer Texas
/in FBAR Lawyers, Legal Notes /by ManagerIf you reside in Waco, Texas and have unreported foreign bank and financial accounts, you may be looking for a Waco FBAR Attorney. Sherayzen Law Office, Ltd. is a leader in FBAR compliance, including offshore voluntary disclosures concerning delinquent FBARs, consider us in your search. Let’s understand why this is the case. Waco FBAR Attorney: International Tax Lawyer First of […]
IRS Sports Industry Campaign: Sport Teams and Owners Targeted
/in Legal Notes, tax lawyer St. Paul Minnesota /by ManagerOn January 16, 2024, the IRS Large Business and International division announced a new compliance campaign: the IRS Sports Industry Campaign. While the announcement is recent and certain details are not yet available, let’s discuss the general direction of this IRS new compliance tax enforcement effort. IRS Sports Industry Campaign: Background Information In the mid-2010s, after […]
June 17 Connecticut Deadline Tax Relief | US Tax Lawyer & Attorney
/in Legal Notes, Tax Lawyers Minneapolis /by ManagerOn January 22, 2024, the Internal Revenue Service announced tax relief for individuals and businesses in parts of Connecticut affected by severe storms, flooding and a potential dam breach that began on January 10, 2024. These taxpayers now have until June 17, 2024, to file various federal individual and business tax returns and make tax payments. June […]
Oklahoma Streamlined Disclosure Lawyer | International Tax Attorney
/in Legal Notes, Streamlined Domestic Offshore Procedures /by ManagerOklahoma is a home to a growing immigrant community with at least 6% of the population foreign-born and another 6% of the population that has at least one immigrant parent. The top countries of original for immigrants are: Mexico, Vietnam, India, Germany (a major surprise to many people) and Guatemala. Many of these new US taxpayers own […]
Plano Foreign Trust Attorney | International Tax Lawyer Texas
/in FBAR Lawyers, foreign trust lawyer, International Tax Attorney, Legal Notes /by ManagerIf you live in Plano, Texas, and you are an owner or a beneficiary of a foreign trust, you need to secure the help of a Plano Foreign Trust Attorney to properly comply with US international tax laws. You should consider retaining Sherayzen Law Office as your Plano Foreign Trust Attorney. Sherayzen Law Office is […]
Houston FBAR Attorney | International Tax Lawyer Texas
/in FBAR Lawyers, Legal Notes /by ManagerIf you reside in Houston, Texas and have unreported foreign bank and financial accounts, you may be looking for a Houston FBAR Attorney. Sherayzen Law Office, Ltd. is a leader in FBAR compliance, including offshore voluntary disclosures concerning delinquent FBARs, consider us in your search. Let’s understand why this is the case. Houston FBAR Attorney: International Tax Lawyer First of […]
First Quarter 2024 IRS Interest Rates on Overpayment & Underpayment of Tax
/in Legal Notes, tax lawyer St. Paul Minnesota /by ManagerOn November 17, 2023, the IRS announced that the First Quarter 2024 IRS interest rates on overpayment and underpayment of tax will not change from the Fourth Quarter of 2023. This means that, the First Quarter 2024 IRS interest rates will be as follows: Internal Revenue Code (“IRC”) §6621 establishes the IRS interest rates on overpayments and underpayments of tax. Under §6621(a)(1), […]
2024 SDOP Audit | Streamlined Domestic Offshore Procedures Lawyer
/in IRS Audit Lawyers, Legal Notes, offshore voluntary disclosure lawyers Minneapolis /by ManagerAn increasing number of submissions under the Streamlined Domestic Offshore Procedures (SDOP) has been subject to an IRS audit; this trend will undoubtedly continue in 2024. In this article, I will explain what an 2024 SDOP Audit is and what a taxpayer should expect during the Audit. 2024 SDOP Audit: Background Information on Streamlined Domestic Offshore Procedures Streamlined Domestic […]
Minneapolis Foreign Trust Attorney | International Tax Lawyer
/in foreign trust lawyer, Legal Notes /by ManagerIf you live in Minneapolis, Minnesota, and you are an owner or a beneficiary of a foreign trust, you need to secure the help of a Minneapolis Foreign Trust Attorney to properly comply with US international tax laws. You should consider retaining Sherayzen Law Office as your Minneapolis Foreign Trust Attorney. Sherayzen Law Office is […]
Denver FBAR Attorney | International Tax Lawyer Colorado
/in FBAR Lawyers, Legal Notes /by ManagerIf you reside in Denver, Colorado and have unreported foreign bank and financial accounts, you may be looking for a Denver FBAR Attorney. Sherayzen Law Office, Ltd. (“Sherayzen Law Office”) is a leader in FBAR compliance and you should consider us in your search. Let’s understand why this is the case. Denver FBAR Attorney: International Tax Lawyer First of all, it […]
Streamlined Domestic Offshore Procedures Lawyer: 2024 SDOP Advantages
/in Legal Notes, offshore voluntary disclosure lawyers Minneapolis, Streamlined Domestic Offshore Procedures /by ManagerSince 2014, Streamlined Domestic Offshore Procedures (“SDOP”) has probably been the most popular offshore voluntary disclosure option, and I predict that it will remain so in the year 2024. In this article, I would like to explore main four 2024 SDOP advantages which US taxpayers should take into account while considering an offshore voluntary disclosure this year. 2024 […]
Indiana Streamlined Disclosure Lawyer | International Tax Attorney
/in Legal Notes, Offshore Voluntary Disclosure /by ManagerIndiana is a home to a small but growing immigrant community with at least 5% of the population foreign-born and another 5% of the population that has at least one immigrant parent. The top countries of original for immigrants are: Mexico, India, China, Myanmar and the Philippines. Many of these new US taxpayers own assets in foreign countries and […]
Cambridge FBAR Attorney | International Tax Lawyer Massachusetts
/in FBAR Lawyers, Legal Notes /by ManagerIf you reside in Cambridge, Massachusetts and have unreported foreign bank and financial accounts, you may be looking for a Cambridge FBAR Attorney. Sherayzen Law Office, Ltd. (“Sherayzen Law Office”) is a leader in FBAR compliance and you should consider us in your search. Let’s understand why this is the case. Cambridge FBAR Attorney: International Tax Lawyer First of all, it […]
Streamlined Domestic Offshore Procedures Lawyer: 2024 SDOP Eligibility Requirements
/in Legal Notes, offshore voluntary disclosure lawyers Minneapolis /by ManagerThe introduction of the Streamlined Domestic Offshore Procedures (SDOP) in 2014 meant that the IRS finally recognized that there was a very large number of U.S. taxpayers who were non-willful with respect to their inability to comply with numerous obscure complex requirements of U.S. tax laws. Since 2014, SDOP has been a highly successful voluntary disclosure option that […]
Ohio Streamlined Disclosure Lawyer | International Tax Attorney
/in Legal Notes, Offshore Voluntary Disclosure /by ManagerOhio has a growing immigrant community with at least 5% of the population foreign-born and another 5% of the population that has at least one immigrant parent. The top countries of original for immigrants are: India, Mexico, China, the Philippines and Canada; more than half of them are naturalized US citizens and more than 42% of them […]
Worcester FBAR Attorney | International Tax Lawyer Massachusetts
/in FBAR Lawyers, Legal Notes /by ManagerIf you reside in Worcester, Massachusetts, and you have unreported foreign bank and financial accounts, you may be looking for Worcester FBAR Attorney. In your search, please consider Mr. Eugene Sherayzen of Sherayzen Law Office, Ltd. (“Sherayzen Law Office”). Let’s understand why this is the case. Worcester FBAR Attorney: International Tax Lawyer First of all, it is very important to […]
Wisconsin Streamlined Disclosure Lawyer | International Tax Attorney
/in Legal Notes, Offshore Voluntary Disclosure /by ManagerWisconsin has a small but rapidly growing immigrant community with at least 5% of the population foreign-born and another 5% of the population that has at least one immigrant parent. The top countries of original for immigrants are: Mexico, India, China, Laos and the Philippines. Many of these new US taxpayers own assets in foreign countries […]
2024 IRS Standard Mileage Rates | IRS Tax Lawyer & Attorney
/in International Tax Attorney Minnesota Minneapolis, Legal Notes /by ManagerBeginning January 1, 2024, the IRS changed the optional standard mileage for the calculation of deductible costs of operating an automobile (sedans, vans, pickups and panel trucks) for business, charitable, medical or moving purposes. Let’s discuss in more detail these new 2024 IRS Standard Mileage Rates. 2024 IRS Standard Mileage Rates for Business Usage For the tax year 2024, […]
Boston FBAR Attorney | International Tax Lawyer Massachusetts
/in FBAR Lawyers, Legal Notes /by ManagerIf you reside in Boston, Massachusetts, and you have unreported foreign bank and financial accounts, you may be looking for Boston FBAR Attorney. In your search, please consider Mr. Eugene Sherayzen of Sherayzen Law Office, Ltd. (“Sherayzen Law Office”). Let’s understand why this is the case. Boston FBAR Attorney: International Tax Lawyer First of all, it is very important to […]
Singapore Solution Fraud Scheme Co-Creator Pleads Guilty | SDOP lawyer Minneapolis
/in Legal Notes, offshore voluntary disclosure lawyers Minneapolis /by ManagerOn December 21, 2023, the IRS and the US Department of Justice announced that Mr. Rolf Schnellmann, a Swiss national, pleaded guilty to conspiring to defraud the United States for his role in the creation and implementation of a fraud scheme related to foreign accounts and foreign income called “Singapore Solution”. In this small essay, I […]
Duluth FBAR Attorney | International Tax Lawyer Minnesota
/in FBAR Lawyers, Legal Notes /by ManagerIf you reside in Duluth, Minnesota, and you have unreported foreign bank and financial accounts, you may be looking for Duluth FBAR Attorney. In your search, please consider Mr. Eugene Sherayzen of Sherayzen Law Office, Ltd. (“Sherayzen Law Office”). Let’s understand why this is the case. Duluth FBAR Attorney: International Tax Lawyer First of all, it is very important to […]
2023 FBAR Conversion Rates | FBAR International Tax Lawyer
/in FBAR, Legal Notes /by ManagerThe 2023 FBAR conversion rates are very important for your US international tax compliance. The reason for their importance is their relation to FBAR (FinCEN Form 114) and the IRS Form 8938. The 2023 FBAR and 2023 Form 8938 instructions both require that 2023 FBAR conversion rates be used to report the required highest balances of foreign financial assets on these […]
St Paul FBAR Attorney | International Tax Lawyer Minnesota
/in FBAR Lawyers, Legal Notes /by ManagerIf you reside in St Paul, Minnesota, and you have unreported foreign bank and financial accounts, you may be looking for St Paul FBAR Attorney. In your search, please consider Mr. Eugene Sherayzen of Sherayzen Law Office, Ltd. (“Sherayzen Law Office”). Let’s understand why this is the case. St Paul FBAR Attorney: International Tax Lawyer First of all, it is […]
US GAAP Conversion of Foreign Financials: Most Common Issues | Form 5471 Lawyer
/in form 5471, Legal Notes /by ManagerForm 5471 generally requires US GAAP (Generally Accepted Accounting Practices) conversion of foreign financial statements for the purposes of reporting book income, because foreign accountants usually prepare these statements based on a different foreign standard. While Treas. Reg. Reg. §1.964-1(a)(2) contains a limited exception to the US GAAP conversion adjustments for “non-material” items (the same exception applies to […]
Plano FBAR Attorney | International Tax Lawyer Texas
/in FBAR Lawyers, Legal Notes /by ManagerIf you reside in Plano, Texas, and you have unreported foreign bank and financial accounts, you may be looking for Plano FBAR Attorney. In your search, please consider Mr. Eugene Sherayzen of Sherayzen Law Office, Ltd. (“Sherayzen Law Office”). Let’s understand why this is the case. Plano FBAR Attorney: International Tax Lawyer First of all, it is very important to […]
Galveston FBAR Attorney | International Tax Lawyer Texas
/in FBAR Lawyers, Legal Notes /by ManagerIf you are a resident of Galveston, Texas, and you have unreported foreign bank and financial accounts, you may be looking for Galveston FBAR Attorney. In your search, consider Mr. Eugene Sherayzen of Sherayzen Law Office, Ltd. (“Sherayzen Law Office”). Let’s understand why this is the case. Galveston FBAR Attorney: International Tax Lawyer First of all, it is […]
Sugar Land FBAR Attorney | International Tax Lawyer Texas
/in FBAR Lawyers, Legal Notes /by ManagerIf you are a resident of Sugar Land (Texas) and you have unreported foreign bank and financial accounts, you may be looking for Sugar Land FBAR Attorney in Texas. In your search, you should consider Mr. Eugene Sherayzen of Sherayzen Law Office, Ltd. (“Sherayzen Law Office”). Let’s understand why this is the case. Sugar Land FBAR Attorney: International […]
The Woodlands FBAR Attorney | International Tax Lawyer Texas
/in FBAR Lawyers, Legal Notes /by ManagerIf you are a resident of The Woodlands (Texas) and you have unreported foreign accounts, you may be looking for The Woodlands FBAR Attorney in Texas. In your search, you should consider Mr. Eugene Sherayzen of Sherayzen Law Office, Ltd. (“Sherayzen Law Office”). Let’s explore in more detail why this is the case. The Woodlands FBAR Attorney: International […]
2024 Form 5471 Penalties | International Tax Lawyer & Attorney
/in IRS Form 5471, Legal Notes /by ManagerFailure to timely and correctly submit Form 5471 with a US tax return may lead to an imposition of Form 5471 penalties. In this article, I will discus the most important 2024 Form 5471 penalties that US taxpayers may face if they fail to comply with the Form 5471 requirements. 2024 Form 5471 Penalties: Purpose of Form 5471 We first need to understand […]
2024 Streamlined Domestic Offshore Procedures: Pros and Cons
/in Lead Article, offshore voluntary disclosure lawyers Minneapolis, Streamlined Domestic Offshore Procedures /by ManagerAs was the case in the year 2023, I expect that Streamlined Domestic Offshore Procedures will continue to be the flagship offshore voluntary disclosure option in 2024 for US taxpayers who reside in the United States. This is why noncompliant US taxpayers should understand well the main advantages and disadvantages of participating in the 2024 Streamlined Domestic […]
Happy New Year 2024 From International Tax Law Firm Sherayzen Law Office!!!
/in International Tax Attorney Minnesota Minneapolis, Legal Notes /by ManagerDear clients, followers, readers and colleagues: Mr. Eugene Sherayzen, an international tax attorney, and the entire international tax team of Sherayzen Law Office, Ltd. wishes you a very Happy New Year 2024!!! Dear clients and prospective clients, in the New Year 2024, you can continue to rely on Sherayzen Law Office for: In resolving all of your current […]
Minnesota FBAR Tax Attorney | International Tax Lawyer
/in FBAR lawyers Minnesota, Legal Notes /by ManagerIf you are looking for a Minnesota FBAR tax attorney, consider retaining the services of Mr. Eugene Sherayzen of Sherayzen Law Office, Ltd. (“Sherayzen Law Office”). Mr. Sherayzen is an international tax attorney and founder of Sherayzen Law Office. Minnesota FBAR tax attorney: FBAR Specialization of an International Tax Attorney The definition of a Minnesota FBAR tax attorney includes […]
2023 Form 3520-A Deadline in 2024 | Foreign Trust Tax Lawyer & Attorney
/in foreign trust lawyer, Legal Notes /by ManagerForm 3520-A is a very important US international information return. It can be very complex and has somewhat tricky filing requirements as well as significant noncompliance penalties. In order to avoid these penalties, you need to file a correct Form 3520-A timely. In this essay, I will discuss the 2023 Form 3520-A deadline in the calendar year 2024. 2023 Form 3520-A Deadline: […]
2023 Form 3520 Deadline in 2024 | Foreign Trust Tax Lawyer & Attorney
/in foreign trust lawyer, Legal Notes /by ManagerForm 3520 is one of the most important US international information returns. Due to its severe penalty structure, it is important to file it timely. In this brief essay, I will discuss the tax year 2023 Form 3520 deadline. 2023 Form 3520 Deadline: What is Form 3520 IRS Form 3520 is a US international information return used by the IRS to collect […]
2023 Form 5471 Deadline in 2024 | International Tax Lawyer & Attorney
/in IRS Form 5471, Legal Notes /by ManagerIRS Form 5471 is one of the most important US international information returns. In this brief essay, I will discuss the tax year 2023 Form 5471 deadline in the calendar year 2024. 2023 Form 5471 Deadline: What is Form 5471 Form 5471 is a US international information return. In general, the IRS uses Form 5471 to collect information about certain US persons who are officers, directors, or shareholders in […]
2023 FBAR Deadline in 2024 | FinCEN Form 114 International Tax Lawyer & Attorney
/in FBAR, Legal Notes /by ManagerThe 2023 FBAR deadline is a critical deadline for US taxpayers this calendar year 2024. What makes FBAR so important are the draconian FBAR penalties which may be imposed on noncompliant taxpayers. Let’s discuss the 2023 FBAR deadline in more detail. 2023 FBAR Deadline: Background Information The official name of FBAR is FinCEN Form 114, the Report of Foreign Bank and Financial Accounts. US […]
2024 Streamlined Foreign Offshore Procedures | US International Tax Law Firm
/in Lead Article, offshore voluntary disclosure lawyers Minneapolis, Streamlined Foreign Offshore Procedures /by ManagerStreamlined Foreign Offshore Procedures has been the best voluntary disclosure option since its creation in 2014 for eligible US taxpayers with undisclosed foreign assets and foreign income, and I predict that it will remain so in the year 2024. Let’s discuss in more detail the unique advantages of the 2024 Streamlined Foreign Offshore Procedures. 2024 Streamlined Foreign Offshore Procedures: Background […]
2024 Offshore Voluntary Disclosure Options | International Tax Lawyer
/in Lead Article, Offshore Voluntary Disclosure /by ManagerEven as the year 2023 nears its end, numerous taxpayers continue to be substantially noncompliant with various US international tax laws. Hence, it is important for US taxpayers with undisclosed foreign assets to consider their 2024 offshore voluntary disclosure options. In this essay, I would like to provide an overview of these 2024 offshore voluntary disclosure options. 2024 Offshore Voluntary Disclosure […]
2023 IRS Quarterly Interest Rates on Overpayment/Underpayment of Tax
/in Legal Notes, tax lawyer St. Paul Minnesota /by ManagerThe 2023 IRS quarterly interest rates IRS interest rates are relevant for a great variety of purposes. Let’s highlight three of its most important uses. First, these rates will determine the interest a taxpayer will get on any IRS refunds. Second, the 2023 IRS quarterly interest rates will also be used to establish the interest […]
2023 Streamlined Domestic Offshore Procedures: Pros and Cons
/in Lead Article, Streamlined Domestic Offshore Procedures /by ManagerUS taxpayers with undisclosed foreign assets and foreign income need to consider their 2023 offshore voluntary disclosure options. As was the case in the year 2022, I expect that Streamlined Domestic Offshore Procedures will continue to be the flagship voluntary disclosure option in 2023 for US taxpayers who reside in the United States. This is […]
Child FBAR Obligations | FBAR Tax Lawyer & Attorney
/in FBAR Lawyers, Legal Notes /by ManagerChild FBAR filing obligations is a topic that comes up fairly often in my practice. In this short essay, I will discuss whether a child is required to file an FBAR and how it should be done. Child FBAR Obligations: What is FBAR FBAR is a common abbreviation for the Report of Foreign Bank and […]
Tax Treaty Election FBAR Obligations | FBAR Lawyer & Attorney
/in FBAR Lawyers, Legal Notes /by ManagerIn my practice, I often receive calls from people who are confused about their FBAR obligations. A recent call raised an important issue of whether a tax treaty election may affect one’s FBAR obligations. In this brief article, I would like to address this issue of tax treaty election FBAR obligations.
Form 114 US Person Definition | FBAR Tax Lawyer
/in FBAR Lawyers, Legal Notes /by ManagerFinCEN Form 114 US Person definition is a highly important component of FBAR and US international tax compliance. In this essay, I will discuss in detail the FinCEN Form 114 US Person definition and highlight some common issues that arise with respect to this definition.
2022 FBAR Conversion Rates | FBAR Tax Lawyer & Attorney
/in FBAR, Legal Notes /by ManagerThe 2022 FBAR conversion rates are very important for your US international tax compliance. The reason for their importance is their relation to FBAR (FinCEN Form 114) and the IRS Form 8938. The 2022 FBAR and 2022 Form 8938 instructions both require that 2022 FBAR conversion rates be used to report the required highest balances […]
2022 Required Minimum Distributions | Tax Lawyer Minneapolis
/in international tax lawyer minnesota, Legal Notes /by ManagerOn December 12, 2022, the Internal Revenue Service reminded those who were born in 1950 or earlier that funds in their retirement plans and individual retirement arrangements face important upcoming deadlines for the 2022 required minimum distributions to avoid penalties. What are the 2022 Required Minimum Distributions? Required minimum distributions, or RMDs, are minimum amounts […]
2022 Fourth Quarter IRS Interest Rates (Underpayment & Overpayment)
/in irs lawyer minneapolis, Legal Notes /by ManagerOn August 15, 2022, the IRS announced that the 2022 Fourth Quarter IRS interest rates will again increase for both underpayment and overpayment cases. This increase closely follows the Federal Reserve’s recent increases in interest rates. This means that, the 2022 Fourth Quarter IRS interest rates will be as follows: Under the Internal Revenue Code, […]
Establishing Cost-Basis in Foreign Real Estate | IRS Audit Tax Lawyer & Attorney
/in International Tax Attorney, IRS Audit Lawyers, Legal Notes /by ManagerOne of the most challenging issues during an IRS audit is establishing cost-basis in foreign real estate. This issue most frequently comes up in the context of real estate that was obtained through inheritance or gift many years ago. In this article, based on my IRS audit experiences, I would like to discuss the main […]
Tax Residency Starting Date | International Tax Lawyer & Attorney
/in international tax lawyer, Legal Notes /by ManagerIn situations where a person was not classified as a resident alien at any time in the preceding calendar year and he became a resident alien at some point during current year, a question often arises concerning the tax residency starting date of such a person. This article seeks to provide a succinct overview of […]
2022 2Q IRS Interest Rates | US International Tax Lawyers
/in international tax lawyer, Legal Notes /by ManagerOn February 23, 2022, the Internal Revenue Service (“IRS”) announced that the 2022 Second Quarter IRS underpayment and overpayment interest rates (“2022 2Q IRS Interest Rates”) will increase from the first quarter of 2022. This means that, the 2022 2Q IRS interest rates will be as follows: The second quarter will start on April 1, […]
Offshore Voluntary Disclosure Seminar | MSBA, February 22 2022
/in Legal Notes, offshore voluntary disclosure lawyers Minneapolis /by ManagerOn February 22, 2022, Mr. Eugene Sherayzen, an international tax attorney and founder of Sherayzen Law Office, Ltd., presented at a seminar “IRS Voluntary Disclosure Options for U.S. Owners of a Foreign Business” (the “Offshore Voluntary Disclosure Seminar”). The Offshore Voluntary Disclosure Seminar was sponsored by the International Business Law Section of the Minnesota State […]
Austin Business Trip | February 2022 | International Tax Lawyer & Attorney
/in international tax lawyer, Legal Notes /by ManagerIn early February of 2022, Mr. Sherayzen, an international tax attorney and owner of Sherayzen Law Office, Ltd., traveled to Austin, Texas. Let’s discuss this Austin business trip in more detail. Austin Business Trip: Goals While the business trip to Austin was very short, Mr. Sherayzen set forth three main goals for the trip: (1) […]
2021 Form 3520-A Deadline in 2022 | Foreign Trust Tax Lawyer & Attorney
/in foreign trust lawyer, Legal Notes /by ManagerForm 3520-A is a very important US international information return. It can be very complex and has somewhat tricky filing requirements as well as significant noncompliance penalties. In order to avoid these penalties, you need to file a correct Form 3520-A timely. In this essay, I will discuss the 2021 Form 3520-A deadline in the […]
Austin Streamlined Disclosure Lawyer | International Tax Attorney
/in Legal Notes, Streamlined Domestic Offshore Procedures /by ManagerAustin is a fast-growing city which attracts a large number of immigrants with assets in foreign countries. These assets may also generate foreign income which their owners must disclose on their US tax returns. Unfortunately many of these new residents of Austin have not correctly reported their foreign assets and foreign income to the IRS. […]
2021 Form 5471 Deadline in 2022 | Foreign Business Tax Lawyer & Attorney
/in IRS Form 5471, Legal Notes /by ManagerIRS Form 5471 is one of the most important US international information returns. In this brief essay, I will discuss the tax year 2021 Form 5471 deadline in the calendar year 2022. 2021 Form 5471 Deadline: What is Form 5471 Form 5471 is a US international information return. In general, the IRS uses Form 5471 […]
2021 Form 3520 Deadline in 2022 | Foreign Trust Tax Lawyer & Attorney
/in foreign trust lawyer, Legal Notes /by ManagerThe beginning of a new tax season starts the clock on completing the required US international information returns, including Form 3520. In this brief essay, I will discuss the tax year 2021 Form 3520 deadline. 2021 Form 3520 Deadline: What is Form 3520 ? IRS Form 3520 is a US international information return used by […]
2021 FBAR Deadline in 2022 | FinCEN Form 114 International Tax Lawyer & Attorney
/in FBAR, Legal Notes /by ManagerThe 2021 FBAR deadline is a critical deadline for US taxpayers this calendar year 2022. What makes FBAR so important are the draconian FBAR penalties which may be imposed on noncompliant taxpayers. Let’s discuss the 2021 FBAR deadline in more detail. 2021 FBAR Deadline: Background Information The official name of FBAR is FinCEN Form 114, […]
2022 Offshore Voluntary Disclosure Options | US International Tax Lawyers
/in Lead Article, offshore voluntary disclosure lawyers Minneapolis /by ManagerWhile the year 2021 has ended, numerous taxpayers continue to be substantially noncompliant with various US international tax laws. Hence, it is important for US taxpayers with undisclosed foreign assets to consider their 2022 offshore voluntary disclosure options. In this essay, I would like to provide an overview of these 2022 offshore voluntary disclosure options. […]
San Antonio FBAR Attorney | International Tax Lawyers Texas
/in FBAR Lawyers, Legal Notes /by ManagerIf you have foreign financial accounts and reside in San Antonio (Texas), you would be looking for a San Antonio FBAR Attorney in Texas. In your search, you could consider out-of-state attorneys such as Mr. Eugene Sherayzen of Sherayzen Law Office, Ltd. (“Sherayzen Law Office”). Let’s explore in more detail why this is the case. […]
2021 FBAR Conversion Rates | FBAR Tax Lawyer & Attorney
/in FBAR, Legal Notes /by ManagerThe 2021 FBAR conversion rates are highly important in US international tax compliance. The 2021 FBAR and 2021 Form 8938 instructions both require that 2021 FBAR conversion rates be used to report the required highest balances of foreign financial assets on these forms (in the case of Form 8938, the 2021 FBAR conversion rates is […]
San Diego FBAR Attorney | International Tax Lawyers California
/in FBAR Lawyers, Legal Notes /by ManagerIf you have foreign financial accounts and reside in San Diego (California), you would be looking for a San Diego FBAR Attorney in California. In your search, you could consider out-of-state attorneys such as Mr. Eugene Sherayzen of Sherayzen Law Office, Ltd. (“Sherayzen Law Office”). Let’s explore in more detail why this is the case. […]
Factual Basis & Tax Planning | International Tax Lawyer & Attorney
/in international tax lawyer Minnesota Minneapolis, Legal Notes /by ManagerIn a previous article, I discussed the necessity of balancing international tax planning priorities in order to obtain an optimal tax result. In this article, I will explain why international tax planning should be based on a carefully-studied factual basis. Factual Basis as the Foundation for International Tax Planning Young inexperienced lawyers often come up […]
Los Angeles FBAR Attorney | International Tax Lawyer California
/in FBAR lawyers Los Angeles, Legal Notes /by ManagerIf you have foreign financial accounts and reside in Los Angeles (California), you would be looking for a Los Angeles FBAR Attorney in California. In your search, you might consider out-of-state attorneys such as Mr. Eugene Sherayzen of Sherayzen Law Office, Ltd. (“Sherayzen Law Office”). Let’s explore in more detail why this is the case. […]
Subsidiary vs. Branch | International Business Tax Lawyer Minneapolis
/in international tax lawyer, Legal Notes /by ManagerFor the purposes of US international tax laws, it is very important to distinguish a subsidiary from a branch. Let’s define both terms in this short essay. Subsidiary vs. Branch: Definition of a Branch A branch is a direct form of doing business by a corporation in another country where the corporation retains the direct […]
San Francisco FBAR Attorney | International Tax Lawyer California
/in FBAR Lawyers, Legal Notes /by ManagerIf you have foreign financial accounts and reside in San Francisco (California), you should be looking for a San Francisco FBAR Attorney in California. In your search, you could consider out-of-state attorneys such as Mr. Eugene Sherayzen of Sherayzen Law Office, Ltd. (“Sherayzen Law Office”). Let’s explore in more detail why this is the case. […]
International Tax Planning Priorities for US Corporations
/in business tax attorney Minneapolis, Legal Notes /by ManagerSometimes, I encounter in my practice one particularly damaging belief concerning international tax planning for US corporations that engage in cross-border transactions and maintain a foreign subsidiary or a network of foreign subsidiaries. This is a belief that international tax planning for such corporations should only focus on the reduction of its US taxes above […]
Foreign Partnership Definition | International Business Tax Lawyers
/in international tax lawyer, Legal Notes /by ManagerDefining a partnership as “foreign” or “domestic” can be highly important for US tax purposes. In this article, I will explain the foreign partnership definition and explain its significance. Foreign Partnership Definition: Importance There may be important US international tax law consequences that stem from whether a partnership is classified as “foreign” or “domestic”. These […]
Berkeley FBAR Attorney | International Tax Lawyers California
/in FBAR Lawyers, Legal Notes /by ManagerIf you have foreign financial accounts and reside in Berkeley (California), you would be looking for a Berkeley FBAR Attorney in California. In your search, consider out-of-state attorneys such as Mr. Eugene Sherayzen of Sherayzen Law Office, Ltd. (“Sherayzen Law Office”). Let’s explore in more detail why this is the case. Berkeley FBAR Attorney: International […]
Happy New Year 2022 From Sherayzen Law Office!!!
/in international tax lawyer, Legal Notes /by ManagerDear clients, followers, readers and colleagues: Sherayzen Law Office wishes you a very Happy New Year 2022!!! For those of you who are currently not in compliance with their US international tax reporting obligations, including FBAR or FinCEN Form 114, we wish you to successfully resolve your prior noncompliance in this new year 2022 with […]
Oakland FBAR Attorney | International Tax Lawyers California
/in FBAR Lawyers, Legal Notes /by ManagerIf you reside in Oakland (California) and have foreign accounts, you would be looking for a Oakland FBAR Attorney in California. In your search, consider out-of-state attorneys such as Mr. Eugene Sherayzen of Sherayzen Law Office, Ltd. (“Sherayzen Law Office”). Let’s explore in more detail why this is the case. Oakland FBAR Attorney: International Tax […]
Sacramento FBAR Attorney | International Tax Lawyer California
/in FBAR Lawyers, Legal Notes /by ManagerIf you are a resident of Sacramento (California) and you have foreign accounts, you would be looking for a Sacramento FBAR Attorney in California. In your search, you could consider out-of-state attorneys such as Mr. Eugene Sherayzen of Sherayzen Law Office, Ltd. (“Sherayzen Law Office”). Let’s explore in more detail why this is the case. […]
Bozeman FBAR Attorney | FATCA Tax Lawyer Montana
/in FBAR Lawyers, Legal Notes /by ManagerIf you are looking for a Bozeman FBAR Attorney in Montana, the recommendation is that you retain the services of Mr. Eugene Sherayzen of Sherayzen Law Office, Ltd. (“Sherayzen Law Office”). Mr. Sherayzen is an FBAR Attorney and founder of Sherayzen Law Office. Bozeman FBAR Attorney: International Tax Attorney It is very important to understand […]
Oregon Streamlined Disclosure Lawyer | International Tax Attorney
/in Legal Notes, Streamlined Domestic Offshore Procedures, Streamlined Foreign Offshore Procedures /by ManagerOregon is a lovely state which hosts a number of immigrants from many different countries (especially in Portland, but also Salem and Eugene). Many of these new US taxpayers own assets in foreign countries and receive income generated by these assets. Unfortunately a number of these taxpayers are not in compliance with their US international […]
Foreign Real Estate US Taxpayer Definition | International Tax Lawyer
/in international tax lawyer, Legal Notes /by ManagerThis essay seeks to identify those considered to be a “US Taxpayer” with respect to reporting foreign real estate or income from it to the IRS. In other words, today, I will discuss the foreign real estate US Taxpayer definition. Foreign Real Estate US Taxpayer Definition: IRC §7701(a) The definition of “US taxpayer” for the […]
2022 Form 5471 Penalties | International Tax Lawyer & Attorney
/in IRS Form 5471, Legal Notes /by ManagerFailure to timely and correctly submit Form 5471 with a US tax return may lead to an imposition of Form 5471 penalties. In this article, I will discus the most important 2022 Form 5471 penalties that US taxpayers may face if they fail to comply with the Form 5471 requirements. 2022 Form 5471 Penalties: Purpose […]
2022 Streamlined Foreign Offshore Procedures | International Tax Lawyer
/in Lead Article, offshore voluntary disclosure lawyers Minneapolis, Streamlined Foreign Offshore Procedures /by ManagerStreamlined Foreign Offshore Procedures has been the best voluntary disclosure option for eligible US taxpayers with undisclosed foreign assets and foreign income, and I predict that it will remain so in the year 2022. Let’s discuss in more detail the unique advantages of the 2022 Streamlined Foreign Offshore Procedures. 2022 Streamlined Foreign Offshore Procedures: Background […]
Florida Streamlined Disclosure Lawyer | International Tax Attorney
/in International Tax Attorney, Legal Notes, Streamlined Domestic Offshore Procedures /by ManagerFlorida is one of the most favorite destinations for immigrants as well as US citizens who do business overseas. Many of these taxpayers own assets in foreign countries and receive income generated by these assets. For this reason, Florida is also one of the leading states when it comes to individuals who wish to go […]
2022 Streamlined Domestic Offshore Procedures: Pros and Cons
/in Lead Article, offshore voluntary disclosure lawyers Minneapolis, Streamlined Domestic Offshore Procedures /by ManagerAs the year 2021 winds down, US taxpayers with undisclosed foreign assets and foreign income need to consider their 2022 offshore voluntary disclosure options. As it has been the case since the second half of 2014 (really the year 2018 when the 2014 OVDP was closed), I expect that Streamlined Domestic Offshore Procedures will continue […]
Texas Streamlined Disclosure Lawyer | FBAR FATCA Tax Attorney
/in Legal Notes, Offshore Voluntary Disclosure /by ManagerThe increased emigration to Texas of foreigners and Americans from other states resulted in a higher portion of Texans with undisclosed foreign assets. The vast majority of these Texans are non-willful with respect to their prior reporting noncompliance and, once they discover their prior noncompliance, they look for professional help resolve their US tax noncompliance […]
California Streamlined Disclosure Lawyer | FBAR FATCA Tax Attorney
/in Legal Notes, Streamlined Domestic Offshore Procedures /by ManagerIf you are a California resident with undisclosed foreign assets and you believe that you were non-willful with respect to your prior reporting noncompliance, you would be looking for professional help to bring your US tax affairs into full compliance with US international tax law through Streamlined Domestic Offshore Procedures. In other words, you are […]
Offshore Accounts Voluntary Disclosure Lawyer Spring Texas
/in Legal Notes, Offshore Voluntary Disclosure /by ManagerIf you have undisclosed foreign accounts and you are a resident of Spring, Texas, it is important for you to understand your options in terms of who can help you with the voluntary disclosure of your noncompliant offshore accounts. In this article, I will help you understand your offshore accounts voluntary disclosure lawyer Spring Texas […]
First Quarter 2022 IRS Interest Rates on Overpayment & Underpayment of Tax
/in IRS Lawyers, Legal Notes /by ManagerOn November 23, 2021, the IRS announced that the First Quarter 2022 IRS interest rates on overpayment and underpayment of tax will not change from the Fourth Quarter of 2021. This means that, the First Quarter 2022 IRS interest rates will be as follows: Internal Revenue Code (“IRC”) §6621 establishes the IRS interest rates on […]
CFC Income Recognition: Five Groups | International Tax Lawyer & Attorney
/in International Tax Attorney, Legal Notes /by ManagerOwnership of a Controlled Foreign Corporation (“CFC”) presents unique income tax challenges under US international tax law. One of them is the fact that US shareholders of a CFC may have to recognize CFC income on their US tax returns beyond what is required under US domestic tax laws. In this article, I will introduce […]
Brazilian Mutual Funds: US Tax Obligations | International Tax Lawyer & Attorney
/in international tax lawyer, Legal Notes /by ManagerIt is a common, almost default practice in Brazil to invest in Brazilian mutual funds. While this practice is perfectly innocent for majority of Brazilians, it may present a huge compliance issue for Brazilians who are also US taxpayers. The problem is that this type of an investment draws at least two important US tax […]
2021 FBAR Civil Penalties | IRS FBAR Tax Lawyer & Attorney
/in FBAR Lawyers, Lead Article /by ManagerAs if they were not high enough, the US Congress has obligated the IRS to adjust FBAR civil penalties for inflation on an annual basis. In this article, I will provide a broad overview of the current FBAR penalty system and describe the current 2021 FBAR civil penalties. 2021 FBAR Civil Penalties: Overview of the […]
Pakistani Bank Accounts FBAR & FATCA Compliance | International Tax Lawyer
/in FATCA, FBAR, Legal Notes /by ManagerUS international tax attorney discusses FBAR and FATCA compliance concerning Pakistani bank accounts.
Indian Mutual Funds & US Person’s Tax Obligations | International Tax Attorney
/in international tax lawyer, Lead Article /by ManagerAfter having handled so many offshore voluntary disclosures for my Indian and Indian-American clients, I can clearly see that US tax reporting obligations concerning Indian mutual funds is one of the most troublesome areas for my clients. In this article, I will focus on the three most important US tax reporting requirements that may be […]
2020 FBAR Conversion Rates | FBAR Tax Lawyer & Attorney
/in FBAR, Legal Notes /by adminThe 2020 FBAR conversion rates are highly important in US international tax compliance. The 2020 FBAR and 2020 Form 8938 instructions both require that 2020 FBAR conversion rates be used to report the required highest balances of foreign financial assets on these forms (in the case of Form 8938, the 2020 FBAR conversion rates is […]
2020 FBAR Deadline in 2021 | FinCEN Form 114 International Tax Lawyer & Attorney
/in FBAR Lawyers, Legal Notes /by ManagerThe 2020 FBAR deadline is one of the most important deadlines for US taxpayers this calendar year 2021. What makes FBAR so important are the draconian FBAR penalties which may be imposed on noncompliant taxpayers. Let’s discuss the 2020 FBAR deadline in more detail. 2020 FBAR Deadline: Background Information The official name of FBAR is […]
2021 Tax Filing Season for Tax Year 2020 Starts on February 12 2021
/in international tax lawyer Minnesota Minneapolis, Legal Notes /by ManagerOn 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 […]
January 28 2021 Inbound Transactions Seminar | US International Tax Lawyer
/in International Tax Attorney, Legal Notes /by ManagerOn 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 […]
Inbound Transactions: Non-US Person Definition | International Tax Attorney
/in International Tax Attorney Minnesota Minneapolis, Legal Notes /by ManagerIn 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 Tax Framework | US International Tax Lawyer & Attorney
/in International Tax Attorney, Legal Notes /by ManagerInbound 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 | FBAR International Tax Lawyers
/in FBAR Lawyers, Legal Notes /by Manager2020 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 […]
FBAR Voluntary Disclosure | International Tax Lawyer & Attorney
/in Legal Notes, offshore voluntary disclosure lawyers Minneapolis /by ManagerI often receive calls from prospective clients who talk about FBAR voluntary disclosure. They usually have no clear idea of what is meant by this term and what its requirements are. In this article, I will discuss this concept of FBAR Voluntary Disclosure and explain how this concept covers a variety of offshore voluntary disclosure […]
Beware of Flat-Fee Lawyers Doing Streamlined Domestic Offshore Procedures
/in International Tax Attorney, Legal Notes /by ManagerRecently, I received a number of phone calls and emails from people who complained about incorrect filing of their Streamlined Domestic Offshore Procedures (“SDOP”) packages by lawyers who took their cases on a flat-fee basis. In this article, I would like to discuss why a flat fee is generally not well-suited for a proper SDOP […]
October 31 2020 FBAR Deadline | FBAR Tax Lawyer & Attorney
/in FBAR Lawyers, Legal Notes /by ManagerUS taxpayers can still timely file their 2019 FBAR (Report of Foreign Bank and Financial Accounts) by the new October 31 2020 FBAR deadline. This FBAR deadline extension is highly unusual and requires some explanation. October 31 2020 FBAR Deadline: What is FBAR? The Report of Foreign Bank and Financial Accounts (“FBAR”) is officially known […]
26 U.S.C. Subpart A: Taxation of Recipients of Corporation Distributions
/in International Tax Attorney Minnesota Minneapolis, Legal Notes /by ManagerThis article is a second installment of our series of articles on corporate distributions. Today’s topic is the description of 26 U.S.C. Subpart A, which contains the most important tax provisions for our subsequent discussions of this subject. 26 U.S.C. Subpart A: Purpose 26 U.S.C Subpart A is the first part of Part I of […]
Introduction to Corporate Distributions | US Business Tax Law Firm
/in business tax lawyers minneapolis, Legal Notes /by ManagerThis essay opens our new series of articles which focuses on corporate distributions. The new series will cover the classification, statutory structure and tax treatment of various types of corporation distributions, including redemptions of corporate stock. This first article seeks to introduce the readers to the overall US statutory tax structure concerning corporate distributions. Corporation […]
The Tinkov Case: Concealment of Foreign Assets During Expatriation
/in international tax lawyer, Legal Notes /by ManagerOn March 5, 2020, the Internal Revenue Service (“IRS”) and the U.S. Department of Justice (“DOJ”) announced that Mr. Oleg Tinkov was arrested in London in connection with an indictment concerning concealment of about $1 billion in foreign assets and the expatriation income in connection with these assets. Let’s discuss the Tinkov case in more […]
§318 Entity-Member Attribution Summary | International Tax Lawyer
/in international tax lawyer, Legal Notes /by ManagerIn a previous article, I discussed the IRC (Internal Revenue Code) §318 sidewise attribution limitation. This limitation was the last piece in the jigsaw puzzle of the §318 entity-member attribution rules; now, we are ready to summarize these rules in light of this exception. This is the purpose of this article – state the §318 […]
July 15 Deferral: More Deadlines Affected | US International Tax News
/in International Tax Attorney, Legal Notes /by ManagerOn April 9, 2020, the IRS announced additional relief to taxpayers by moving the due date for more deadlines to July 15, 2020. Let’s discuss this additional July 15 Deferral in more detail. July 15 Deferral: Background Information On March 13, 2020, in response to the 2019 coronavirus (also called “COVID-19″) pandemic, President Trump issued […]
Employee Retention Credit | US Tax Lawyers & Attorneys
/in Legal Notes, Tax Lawyers Minneapolis /by ManagerOn March 31, 2020, the IRS launched the Employee Retention Credit. This new tax credit is designed to encourage businesses to keep employees on their payroll. Let’s discuss the Employee Retention Credit in more detail. Employee Retention Credit: Eligibility Criteria Two categories of employers are not eligible to apply for the Employee Retention Credit: (a) […]
§318 Sidewise Attribution Limitation | US International Tax Attorney
/in International Tax Attorney, Legal Notes /by ManagerThis article explores the third main limitation on the general IRC (Internal Revenue Code) §318 corporate stock re-attribution rules – §318 Sidewise Attribution Limitation. §318 Sidewise Attribution Limitation: What is “Sidewise Attribution”? A sidewise attribution occurs when corporate stock owned by an owner of a business entity (or a beneficiary of a trust or estate) […]
Critical Business Exemption | Minnesota Shelter-In-Place Order
/in business tax lawyers minneapolis, Legal Notes /by ManagerOn March 25 , 2020, the Honorable Tim Walz, Governor of the State of Minnesota, issued a “Shelter-In-Place” Emergency Executive Order 20-20. The Executive Order mandates all persons in Minnesota to stay at home or in their place residence, unless they go out to engage in certain activities or do work for a business which […]
Coronavirus Offshore Voluntary Disclosure: Problems & Opportunities
/in Legal Notes, offshore voluntary disclosure lawyers Minneapolis /by ManagerThe advancement of coronavirus in the United States and around the world has significantly disrupted the normal conditions and assumptions for a US taxpayer who engages in an offshore voluntary disclosure of his unreported foreign income and foreign assets. I will refer to a voluntary disclosure conducted in this context of the coronavirus disruptions as […]
New July 15 Deadline for 2019 Tax Compliance | International Tax News
/in International Tax Attorney, Legal Notes /by ManagerOn March 21, 2020, the IRS moved the federal income tax filing and tax payment due date from April 15, 2020, to July 15, 2020. Let’s discuss the new July 15 deadline in more detail. July 15 Deadline: Why the IRS Moved the Tax Deadline to July 15, 2020? The IRS moved the deadline because […]
Coronavirus & Chinese Offshore Voluntary Disclosures | SDOP Tax Law Firm
/in Legal Notes, offshore voluntary disclosure lawyers Minneapolis /by ManagerThe ongoing coronavirus pandemic has disrupted many areas of human activity around the planet. The coronavirus even affected the IRS offshore voluntary disclosures concerning US taxpayers’ unreported financial assets and income in China (“Chinese Offshore Voluntary Disclosures”). In fact, the impact of coronavirus on the Chinese Offshore Voluntary Disclosures has been severe and extremely disruptive. […]
Family Re-Attribution Limitation Under §318 | International Tax Lawyers
/in international tax lawyer, Legal Notes /by ManagerThis article explores the second limitation on the IRC (Internal Revenue Code) §318 re-attribution rule – family re-attribution limitation. Family Re-Attribution Limitation: General §318 Re-Attribution Rule The general §318 re-attribution rule states that a constructively-owned corporate stock should be treated as actually owned for the purpose of further re-attribution of stock to other persons. §318(a)(5)(A). […]
Hindu Undivided Family (HUF) US Tax Classification | Foreign Trust Lawyer
/in foreign trust lawyer, Legal Notes /by ManagerThis article continues a series of articles concerning US tax classification of unusual foreign entities; our focus is on the determination whether these entities should be classified as foreign business entities or foreign trusts. Today’s topic is the Hindu Undivided Family, the preferred legal entity for managing family estates for a large number of wealthy […]
§318 Double-Inclusion Prohibition | International Tax Lawyers Tampa FL
/in international tax lawyer, Legal Notes /by ManagerIn a previous article, I discussed the IRC (Internal Revenue Code) §318 general rule on the re-attribution of corporate stock; in that context, I mentioned that there are certain restrictions on §318 re-attribution. Today, I would like to discuss one of such restrictions – §318 double-inclusion prohibition. §318 Double-Inclusion Prohibition: General Re-Attribution Rule Before we […]
2020 2Q IRS Interest Rates | US International Tax Law Firm
/in International Tax Attorney Minnesota Minneapolis, Legal Notes /by ManagerOn February 28, 2020, the Internal Revenue Service (“IRS”) announced that the 2020 Second Quarter IRS underpayment and overpayment interest rates (“2020 2Q IRS Interest Rates”) will not change from the first quarter of 2020. This means that, the 2020 2Q IRS interest rates will be as follows: Under the Internal Revenue Code, these interest […]
2020 SDOP Penalty | Offshore Voluntary Disclosure International Tax Attorney
/in Legal Notes, offshore voluntary disclosure lawyers Minneapolis /by ManagerIn an earlier article, I discussed the advantages of the Streamlined Domestic Offshore Procedures (“SDOP”) in the year 2020. Among the advantages, I mentioned the SDOP Miscellaneous Offshore Penalty (hereinafter “SDOP Penalty”), but never explained this concept. The focus of this article is on the 2020 SDOP Penalty and how one generally should calculate it. […]
§318 Re-attribution: General Rule | International Tax Lawyers Miami
/in international tax lawyer, Legal Notes /by ManagerThis article continues a series of articles on the Internal Revenue Code (“IRC”) §318 constructive ownership rules. Today, I would like to focus on the §318 re-attribution rule. In this article, I will explain the general §318 re-attribution rule and mention the exceptions. I will discuss the exceptions in more detail in future articles. §318 […]
Liechtenstein Stiftung: US Tax Classification | Foreign Trust Tax Lawyer
/in foreign trust lawyer, Legal Notes /by ManagerThis article continues a series of articles on foreign trust classification with respect to various foreign entities. Today’s topic is the US tax treatment of a Liechtenstein Stiftung. Liechtenstein Stiftung: Formation A Liechtenstein Stiftung, or Foundation, is a legal entity under Liechtenstein law. It may be formed by filing a foundation charter or by will […]
Liechtenstein Anstalt: US Tax Treatment | Foreign Trust Lawyer & Attorney
/in foreign trust lawyer, Legal Notes /by ManagerOver the years, the IRS has made a number of rulings with respect to whether certain foreign entities should be considered trusts for US tax purposes. In this article, I would like to discuss the US tax classification of Liechtenstein Anstalt based on the 2009 IRS Chief Counsel Advice Memorandum, AM 2009-012. Liechtenstein Anstalt: Creation […]
New Form 1040-SR for Seniors | US Tax Lawyers & Attorneys
/in Legal Notes, tax lawyers st paul /by ManagerFor the very first time, the IRS has created a new tax form called Form “1040-SR”. “SR” here standards for “seniors”. The idea is that the new form will be used by senior taxpayers. Let’s discuss Form 1040-SR in more detail. Form 1040-SR: Reasons for Its Creation The reason for the creation of Form 1040-SR […]
Form 114 Trust Filers | FBAR Tax Lawyer & Attorney Nevada Las Vegas
/in FBAR Lawyers, Legal Notes /by ManagerFinCEN Form 114 trust filers constitute a highly problematic category of FBAR filers. Form 114 trust filers are problematic not so much because the FBAR requirement itself is unclear, but, rather, because the trustees do not realize that this requirement applies to them. In this article, I would like to educate potential Form 114 trust […]
§318 Option Attribution | International Tax Lawyers United States
/in international tax lawyer, Legal Notes /by ManagerA previous article defined “option” for the purposes of the IRC (Internal Revenue Code) §318(a)(4). Today, I will discuss the main §318 option attribution rule. §318 Option Attribution: Main Rule Under §318(a)(4), “if any person has an option to acquire stock, such stock shall be considered as owned by such person.” For the purposes of […]
§318 Option Definition | US International Tax Lawyer & Attorney
/in international tax lawyer, Legal Notes /by ManagerThis article continues our series of articles on the IRC (Internal Revenue Code) §318 constructive ownership rules. In this article, I would like to introduce the readers to the infamous §318 option attribution rules. Before we delve into the discussion of the constructive ownership rules for options, however, it is important to understand what “option” […]
§318 Upstream Corporate Attribution | International Tax Lawyers Florida
/in International Tax Attorney, Legal Notes /by ManagerIn a previous article, I discussed the rules for the downstream attribution of corporate stocks under the IRC (Internal Revenue Code) §318. Today, I would like to discuss the §318 upstream corporate attribution rules. §318 Upstream Corporate Attribution: Two Types of Attribution There are two types of §318 corporate attribution rules: downstream and upstream. Under […]
§318 Downstream Corporate Attribution | Corporate Tax Lawyer & Attorney
/in FBAR Lawyers, international tax lawyer, Legal Notes /by ManagerThis article continues a series of articles on the constructive ownership rules of the IRC (Internal Revenue Code) §318. Today, we will discuss corporate attribution rules, even more specifically the §318 downstream corporate attribution rules. §318 Downstream Corporate Attribution: Two Types of Attribution There are two types of §318 corporate attribution rules: downstream and upstream. […]
2020 IRS Standard Mileage Rates | IRS Tax Lawyer & Attorney
/in International Tax Attorney, Legal Notes /by ManagerBeginning January 1, 2020, the IRS changed the optional standard mileage for the calculation of deductible costs of operating an automobile (sedans, vans, pickups and panel trucks) for business, charitable, medical or moving purposes. Let’s discuss in more detail these new 2020 IRS Standard Mileage Rates. 2020 IRS Standard Mileage Rates for Business Usage For […]
Indian US Dollar Remittances | International Tax Lawyer & Attorney
/in International Tax Attorney, Legal Notes /by ManagerFor some years now, India has remained at the top of all countries that receive remittances in US dollars. A lot of these funds flow from Indian-Americans and Indians who reside in the United States. The problem is that a lot of them are not in compliance with respect to their US international tax obligations […]
§318 Employee Trust Attribution | Foreign Trust US Tax Law Firm
/in foreign trust lawyer, Legal Notes /by ManagerIn a previous article, I explained special §318 rules concerning grantor trusts as an exception to the general §318 trust attribution rules. Today, I will discuss the special §318 employee trust attribution rules as another exception to the general §318 trust attribution rules. §318 Employee Trust Attribution: Focus on Tax-Exempt Employee Trusts First of all, […]
§318 Grantor Trust Attribution | Foreign Trust Tax Lawyer & Attorney
/in foreign trust lawyer, Legal Notes /by ManagerIn previous articles, I discussed the §318 downstream and upstream attribution rules; in that context, I also mentioned that there were special rules concerning grantor trusts and tax-exempt employee trusts. This article will cover the special §318 grantor trust attribution rules. §318 Grantor Trust Attribution: Definition of Grantor Trust A grantor trust is any trust […]
§318 Upstream Trust Attribution | US Foreign Trust Tax Lawyer & Attorney
/in foreign trust lawyer, Legal Notes /by ManagerIn a previous article, I discussed the Internal Revenue Code (“IRC”) §318 downstream trust attribution rules. Today, I would like to focus on the §318 upstream trust attribution rules. §318 Upstream Trust Attribution: Downstream vs. Upstream There are two types of §318 trust attribution: downstream and upstream. In a previous article, I already covered the […]
US Information Returns: Introduction | International Tax Lawyer Minnesota
/in international tax lawyer, Legal Notes /by ManagerIn this article, I would like to introduce the readers to the concept of US information returns; I will also explore the differences between US information returns and US tax returns. US Information Returns: Two Types of Returns The US tax system is a self-assessment system where taxpayers must file certain forms or returns developed […]
FinCEN Form 114 Estate Filers | FBAR Tax Lawyer & Attorney
/in FBAR Lawyers, Legal Notes /by ManagerMany taxpayers and even tax professionals are completely unaware of the fact that FBAR needs to be filed not just by individuals, businesses and trusts, but also by estates. In this article, I will discuss FinCEN Form 114 Estate filers (i.e. estates that need to file FinCEN Form 114). FinCEN Form 114 Estate filers: FBAR […]
§318 Downstream Trust Attribution | Foreign Trust Tax Lawyer & Attorney
/in International Tax Attorney, Legal Notes /by ManagerThe attribution of stock ownership to constructive owners is a highly important feature of US domestic and international tax law. The Internal Revenue Code (“IRC”) §318 contains complex constructive ownership rules concerning corporate stock; these rules vary depending on a specific §318 relationship. This article focuses on an important category of §318 relationships – trusts. […]
§318 Upstream Estate Attribution | International Tax Lawyer & Attorney
/in International Tax Attorney, Legal Notes /by ManagerThis article continues a series of articles concerning the constructive ownership rules of the Internal Revenue Code (“IRC”) §318. Today’s focus is on the §318 upstream estate attribution rules. §318 Estate Attribution Rules: Downstream Attribution vs. Upstream Attribution There are two types of the IRC §318 estate attribution rules: downstream and upstream. In a previous […]
§318 Estate Beneficiary Definition | US International Tax Law Firm
/in international tax lawyer, Legal Notes /by ManagerThe Internal Revenue Code (“IRC”) §318 contains corporate stock attribution rules between an estate and its beneficiaries. In order to apply these rules correctly, one must understand how §318 defines “beneficiary” for the purposes of upstream and downstream estate attribution rules. This articles will introduce the readers to this §318 estate beneficiary definition. §318 Estate […]
§318 Downstream Estate Attribution | International Tax Lawyer & Attorney
/in international tax lawyer, Legal Notes /by ManagerThis article continues a series of articles on the Internal Revenue Code (“IRC”) §318 constructive ownership rules. Today, the topic is §318 estate attribution rules – i.e. attribution of ownership of corporate stock from estate to its beneficiaries and vice versa. Since this is a long topic, I will divide it into three articles. This […]
2020 SDOP Eligibility Requirements | SDOP Tax Lawyer & Attorney
/in Legal Notes, offshore voluntary disclosure lawyers Minneapolis, Streamlined Domestic Offshore Procedures /by ManagerIn a recent article, I mentioned that Streamlined Domestic Offshore Procedures (“SDOP”) will continue to be the most important voluntary disclosure option in 2020 for US taxpayers who reside in the United States. However, not all taxpayers will qualify to participate in the 2020 SDOP. In this article, I will discuss the main 2020 SDOP […]
§318 Partnership Attribution | International Corporate Tax Lawyers
/in business tax lawyers minneapolis, Legal Notes /by ManagerThis article continues a series of articles on the Internal Revenue Code (“IRC”) §318 constructive ownership rules. In this essay, we will discuss the §318 partnership attribution rules – i.e. attribution of ownership of shares from partnership to partners and vice versa. §318 Partnership Attribution Rules: Two Types There are two types of the IRC […]
Ukrainian FATCA IGA Enters Into Force | FATCA Tax Lawyer & Attorney
/in FATCA Lawyers, Legal Notes /by ManagerOn November 18, 2019, the Ukrainian FATCA IGA entered into force. Sherayzen Law Office already wrote on this subject a little more than three years ago. This essay updates the status of the Ukrainian FATCA IGA. Ukrainian FATCA IGA: Background Information The Foreign Account Tax Compliance Act (FATCA) was enacted into law in 2010 and […]
2019 FBAR Conversion Rates | FBAR Tax Lawyer & Attorney
/in FBAR, Legal Notes /by ManagerThe 2019 FBAR conversion rates are highly important in US international tax compliance. The 2019 FBAR and 2019 Form 8938 instructions both require that 2019 FBAR conversion rates be used to report the required highest balances of foreign financial assets on these forms (in the case of Form 8938, the 2019 FBAR conversion rates is […]
2020 Streamlined Domestic Offshore Procedures: Pros and Cons
/in Legal Notes, offshore voluntary disclosure lawyers Minneapolis, Streamlined Domestic Offshore Procedures /by ManagerNoncompliant US taxpayers with undisclosed foreign assets and foreign income should consider their voluntary disclosure options in this new year 2020. Similarly to 2019, I expect that this year Streamlined Domestic Offshore Procedures will continue to be the flagship voluntary disclosure option for such taxpayers who reside in the United States. In order for the […]
IRC §318 Family Attribution | International Tax Law Firm Minnesota
/in International Tax Attorney, Legal Notes /by ManagerIn a previous article, I outlined six main relationship categories of the Internal Revenue Code (“IRC”) §318. In this article, I will focus on the first of these categories: the IRC §318 family attribution rules. §318 Family Attribution: General Rule §318(a)(1)(A) describes the §318 family attribution rule . It states that an individual is a […]
2020 Offshore Voluntary Disclosure Options | US International Tax Lawyers
/in Lead Article, offshore voluntary disclosure lawyers Minneapolis /by ManagerAs the new year 2020 begins, it is important for US taxpayers with undisclosed foreign assets to consider their 2020 offshore voluntary disclosure options. Unlike last year, there have not been any drastic changes to the voluntary disclosure options since 2019. In this article, I would like to generally explore the 2020 offshore voluntary disclosure […]
2019 Tax Filing Season for Individual Filers Opens on January 27 2020
/in international tax lawyer minnesota, Legal Notes /by ManagerOn January 6, 2020, the IRS announced that the 2019 tax filing season will commence on Monday, January 27, 2020. In other words, on that date, the IRS will begin accepting and processing the 2019 tax returns. This year the deadline for the filing of the 2019 tax returns as well as any payment of […]
Partnership Related Party Loss Disallowance | Tax Lawyer & Attorney
/in business tax lawyers minneapolis, Legal Notes /by ManagerIn a series of articles concerning Internal Revenue Code (“IRC”) §267, I discussed various rules concerning related party loss disallowance. In this article, I would like to focus on special rules concerning partnership related party loss disallowance. Partnership Related Party Loss Disallowance: Main IRC Provisions Three IRC sections are most relevant to special rules of […]
§318 Relationship Categories | International Business Tax Lawyer & Attorney
/in International Tax Attorney, Legal Notes /by ManagerIn a previous article I discussed the importance of the Internal Revenue Code (“IRC”) §318 constructive stock ownership rules. Today, I would like to introduce the readers to the various §318 relationship categories – i.e. what types of taxpayers are affected by this section’s constructive ownership rules. §318 Relationship Categories: Related Persons Congress created IRC […]
IRC §318 Importance | International Tax Lawyer & Attorney
/in international tax lawyer, Legal Notes /by ManagerIt is difficult to overstate the significant role the Internal Revenue Code (“IRC”) §318 plays in US corporate tax law and US international tax law. In this article, I will explain the §318 importance and list out major IRC provisions which reference §318. IRC §318 Importance: Fundamental Purpose §318 sets forth the circumstances when the […]
The IRS Hiring Spree in 2019 and 2020 | Tax Lawyer & Attorney
/in Legal Notes, tax lawyer St. Paul Minnesota /by ManagerThe IRS stated in December of 2019 that it hired about 9,500 people during the fiscal year 2019 and it is trying to add another about 5,300 employees as soon as possible. This new IRS hiring spree is meant to reverse the long-term declining trend in IRS employment. The IRS Hiring Spree: 2009-2018 Trend Between […]
§267 Family Attribution | International Tax Lawyer & Attorney
/in international tax lawyer, Legal Notes /by ManagerIn a previous article, I introduced the constructive ownership rules of the Internal Revenue Code (“IRC”) §267. Today, I would like to discuss one of them in more detail – §267 family attribution. §267 Family Attribution: General Rule The §267 family attribution rule is described in §267(c)(2). It states that, for the purposes of determining […]
§267 Entity-to-Member Attribution | International Tax Lawyer & Attorney
/in international tax lawyer minnesota, Legal Notes /by ManagerIn a previous article, I introduced the Internal Revenue Code (“IRC”) §267 constructive ownership rules. Today, I would like to focus specifically on the §267 entity-to-member attribution rule. §267 Entity-to-Member Attribution: General Rule §267(c)(1) describes the §267 entity-to-member attribution rule. It states that stocks owned by a corporation, partnership, estate or trust will be treated […]
§267 Constructive Ownership Rules | International Tax Lawyer & Attorney
/in International Tax Attorney Minnesota Minneapolis, Legal Notes /by ManagerIn a previous article, I discussed the related person definition for the purposes of the Internal Revenue Code (“IRC”) §267. That article, however, focused on the definition itself rather than on a host of supplementary rules necessary to fully understand this definition. In this article, I would like to discuss one set of these rules […]
Related Person Definition – IRC §267 | International Tax Lawyer & Attorney
/in International Tax Attorney, Legal Notes /by ManagerInternal Revenue Code (“IRC”) §267 imposes significant restrictions on the ability of related persons to recognize loss from a transaction that involves a sale or exchange of property. Hence, it is important for a tax attorney who advises on such a transaction to understand the concept of a “related person” in order to properly advise […]
Happy New Year 2020 from Sherayzen Law Office!
/in International Tax Attorney, Legal Notes /by ManagerSherayzen Law Office wishes everyone a very happy and prosperous New Year 2020! We also wish you stay in full US tax compliance with US international tax laws while your tax burden decreases! And, we are here to help our clients to turn these wishes into reality! In the year 2020, Sherayzen Law Office will […]
IRC §267 Purpose | International Tax Lawyer & Attorney Austin TX
/in international tax lawyer, Legal Notes /by ManagerThis brief essay explores the IRC §267 purpose of existence – i.e. Why did Congress decide to enact IRC §267 and in what situations does it generally apply? IRC §267 Purpose: Problematic Scenarios When Congress enacted IRC §267, it meant to address a very specific problem in the context of two scenarios. The problem was […]
Attribution Rules: Introduction | International Tax Lawyer & Attorney
/in International Tax Attorney, Legal Notes /by ManagerOne of the most popular tax reduction strategies is based on shifting an ownership interest in an entity or property to related persons or related entities. In order to prevent the abuse of this strategy, the US Congress has enacted a large number of attribution rules. In this brief essay, I will introduce the concept […]
2020 First Quarter IRS Interest Rates | International Tax Lawyers
/in International Tax Attorney, Legal Notes /by ManagerOn December 6, 2019, the Internal Revenue Service (“IRS”) announced that the 2020 First Quarter IRS underpayment and overpayment interest rates will not change from the 4th Quarter of 2019. This means that, the 2020 First Quarter IRS underpayment and overpayment interest rates will be as follows: Under the Internal Revenue Code, the rate of […]
Post-OVDP Audits | Offshore Voluntary Disclosure Lawyer & Attorney
/in IRS Audit Lawyers, Legal Notes, offshore voluntary disclosure lawyers Minneapolis /by ManagerA significant number of US taxpayers who went through the OVDP mistakenly believed that they were immune from the IRS post-OVDP audits concerning their post-voluntary disclosure compliance. Sherayzen Law Office has repeatedly warned in the past that these taxpayers were mistaken with respect to their exposure to potential post-OVDP audits. The recent announcement of a […]
The Norman Case: Willful FBAR Penalty Upheld | FBAR Lawyers Miami
/in FBAR audit tax attorney, Legal Notes /by ManagerOn November 8, 2019, the Federal Circuit Court of Appeals (the “Court”) upheld the decision of the Court of Federal Claims to uphold the IRS assessment of a willful FBAR penalty in the amount of $803,530 with respect to Ms. Mindy Norman’s failure to file her 2007 FBAR. The Norman case deserves special attention because […]
New FBAR Filing Verification Submission Process | FBAR Lawyer & Attorney
/in FBAR Lawyers, Legal Notes /by ManagerOn November 19, 2019, the IRS announced changes to the current FBAR filing verification submission process. The change is technical, but not without importance.
November 21 2019 BSU Seminar in Minsk, Belarus | International Tax News
/in International Tax Attorney, Legal Notes /by ManagerOn November 21, 2019, Mr. Eugene Sherayzen, an international tax attorney and founder of Sherayzen Law Office, Ltd., conducted a seminar at the Belarusian State University Law School (the “2019 BSU Seminar”) in Minsk, Belarus. Let’s explore the 2019 BSU Seminar in more detail. 2019 BSU Seminar: Topic and Attendance The topic of the seminar […]
Greek Flat Tax Residency: Draft Bill | International Tax Lawyer News
/in International Tax Attorney, Legal Notes /by ManagerThe new Greek government headed by Prime Minister Kyriakos Mitsotakis wishes to reach 2.8% economic growth next year. Part of the plan to achieve this goal includes a tax reform which introduces a curious new concept of Greek flat tax residency for wealthy foreign investors. Let’s discuss this interesting idea in more detail. Greek Flat […]
Foreign Income Reporting Without Forms W-2 or 1099 | Tax Lawyer
/in international tax lawyer, Legal Notes /by ManagerThere is a surprisingly large number of US taxpayers who believe that reporting foreign income that was not disclosed on a Form W-2 or 1099 is unnecessary. Even if they honestly believe it to be true, this erroneous belief exposes these taxpayers to an elevated risk of imposition of high IRS penalties. In this article, […]
The Pursley Case: Offshore Tax Evasion Leads to Criminal Conviction
/in International Tax Attorney, Legal Notes /by ManagerOn September 6, 2019, the Tax Division of the US Department of Justice (“DOJ”) announced another victory against Offshore Tax Evasion. This time, a Houston lawyer, Mr. Jack Stephen Pursley, was convicted of one count of conspiracy to defraud the United States and three counts of tax evasion. Let’s discuss this Pursley Case in more […]
The Booker Case: ex-CPA Indicted for FBAR violations | FBAR Lawyer News
/in Legal Notes, offshore voluntary disclosure lawyers Minneapolis /by ManagerOn August 27, 2019, the US Department of Justice (“DOJ”) announced that a federal grand jury returned a superseding indictment charging Mr. Brian Booker, a former resident of Fort Lauderdale, Florida, whose business specialized in international trade, with failing to file Reports of Foreign Bank and Financial Accounts (“FBARs”) and filing false documents with the […]
July 2019 IRS Compliance Campaigns | International Tax Lawyer & Attorney
/in International Tax Attorney Minnesota Minneapolis, Legal Notes /by ManagerOn July 19, 2019, the IRS Large Business and International division (LB&I) announced the approval of another six compliance campaigns. Let’s discuss in more detail these July 2019 IRS compliance campaigns. July 2019 IRS Compliance Campaigns: Background Information In the mid-2010s, after extensive tax planning, the IRS decided to restructure LB&I in a way that […]
Child’s FBAR Requirements | FBAR Tax Lawyer & Attorney
/in FBAR Lawyers, Legal Notes /by ManagerI often receive questions concerning a child’s FBAR requirements. Many taxpayers automatically assume that, if their children are below the age of majority, these children do not have to file FBARs. Unfortunately, this is not the case – a child’s FBAR requirements are every bit as extensive of those of his parents. Child’s FBAR Requirements: […]
2019 Fourth Quarter IRS Interest Rates | PFIC Tax Lawyers
/in International Tax Attorney, Legal Notes /by ManagerOn August 28, 2019, the Internal Revenue Service (“IRS”) announced that the 2019 Fourth Quarter IRS underpayment and overpayment interest rates will not change from the 3rd Quarter of 2019. This means that, the 2019 Fourth Quarter IRS underpayment and overpayment interest rates will be as follows: Under the Internal Revenue Code, the rate of […]
Sherayzen Law Office Successfully Completes its 2019 Fall Tax Season
/in International Tax Attorney, Legal Notes /by ManagerOn October 15, 2019, Sherayzen Law Office, Ltd., successfully completed its 2019 Fall Tax Season. It was a challenging and interesting tax season. Let’s discuss it in more detail. 2019 Fall Tax Season: Sherayzen Law Office’s Annual Compliance Clients Annual tax compliance is one of the major services offered by Sherayzen Law Office to its […]
Fundamental Form 5471 Concepts | Form 5471 Tax Lawyer & Attorney
/in IRS Form 5471, Legal Notes /by ManagerForm 5471 tax attorney discusses fundamental Form 5471 concepts of US Person, US Shareholder & CFC (Controlled Foreign Corporation)
FATCA Criminal Penalties | International Tax Lawyer & Attorney
/in FATCA Tax Attorney, Legal Notes /by ManagerWhile 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 […]
2019 Minsk Seminar: US International Corporate Tax Reform | GILTI & FDII
/in International Tax Attorney, Legal Notes /by ManagerOn 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 […]
Partnership International Tax Issues | International Tax Lawyer & Attorney
/in International Tax Attorney, Legal Notes /by ManagerThis 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 […]
IRS Acquires Phone-Hacking Software | IRS Lawyer News
/in IRS Lawyers, Legal Notes /by ManagerIt 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 […]
Minnesota Sales Tax Responsible Person Legal Standard | Audit Tax Lawyer
/in Legal Notes, minneapolis tax lawyer /by ManagerIn this article, I would like to discuss the legal definition of Responsible Person under Minn. Stat. § 270C.56 – I will refer to this term as Minnesota sales tax responsible person legal standard. Minnesota Sales Tax Responsible Person: Background Information Minnesota imposes a sales tax “on the gross receipts from retail sales.” Minn. Stat. […]
2019 Zurich Trip Completed | Zurich US International Tax Lawyer & Attorney
/in International Tax Attorney, Legal Notes /by ManagerIn July of 2019, Mr. Eugene Sherayzen, an international tax attorney and owner of Sherayzen Law Office, Ltd., completed his business trip to Zurich, Switzerland. Let’s discuss in more detail this 2019 Zurich Trip, its goals and accomplishments. 2019 Zurich Trip: Goals Mr. Sherayzen outlined the firm’s goals for the Zurich trip during the Sherayzen […]
2019 Karlovy Vary Trip Completed | US International Tax Lawyer & Attorney
/in International Tax Attorney, Legal Notes /by ManagerMr. Eugene Sherayzen, an international tax attorney and owner of Sherayzen Law Office, Ltd., completed his trip to Karlovy Vary, Czech Republic, on July 10, 2019. Let’s discuss in more detail this brief 2019 Karlovy Vary trip, its motivations and results. 2019 Karlovy Vary Trip: Reasons for this Excursion There were several reasons why Mr. […]
Legal Entity Identifiers: Introduction to LEI | International Tax Lawyer & Attorney
/in business tax lawyers minneapolis, Legal Notes /by ManagerThe Legal Entity Identifiers (“LEI”) is a method to identify legal entities that engage in financial transactions. Let’s discuss LEI in more detail. LEI: Background Information The establishment of LEI was driven by the recognition by regulators around the world that there is a complete lack of transparency with respect to identifying parties to international […]
IRS Appeals Video Conference | IRS Tax Lawyer & Attorney
/in IRS Lawyers, Legal Notes /by ManagerIn May of 2019, Mr. Andrew Keyso, a deputy chief of the IRS Office of Appeals, stated that the Appeals Office is in the early stages of rolling out the technology to conduct video conferences as an option for Appeals conferences. This is great news for tax practitioners – an IRS Appeals video conference is […]
Finnish US Bank Accounts Face IRS John Doe Summonses | FATCA News
/in FATCA Lawyers, Legal Notes /by ManagerOn May 1, 2019, the United States District Court for the Western District of North Carolina (the “Court”) authorized the IRS to serve John Doe Summonses seeking information about Finnish residents who own secret US bank accounts (collectively Finnish US Bank Accounts). Let’s discuss this development concerning Finnish US bank accounts in more depth. Finnish […]
PLR TAM Comparison | IRS International Tax Lawyer & Attorney
/in International Tax Attorney, Legal Notes /by ManagerThe IRS Private Letter Rulings (“PLR”) and the IRS Technical Advice Memoranda (“TAM”) often get confused by non-practitioners. In this small essay, I will engage in a brief PLR TAM comparison in order to clarify the similarities and differences between both types of IRS administrative guidance. PLR TAM Comparison: Similarities Let’s begin our PLR TAM […]
IRS Issues FBAR Fact Sheet | FBAR FATCA Tax Lawyer & Attorney
/in FBAR Lawyers, Legal Notes /by ManagerOn April 4, 2019, the IRS issued the FBAR Fact Sheet in order to acquaint US taxpayers with this highly important reporting requirement for foreign accounts held by US persons. Let’s analyze the new fact sheet in more detail. FBAR Fact Sheet: Organizational Structure of the Fact Sheet The IRS FBAR Fact Sheet can be […]
FY 2018 DOJ Criminal Case Statistics | Tax Lawyer & Attorney Minneapolis
/in Legal Notes, offshore voluntary disclosure lawyers Minneapolis /by ManagerAn analysis of the fiscal year 2018 DOJ criminal case statistics reveals certain interesting patterns about federal criminal tax prosecution in that year. Let’s explore in more detail these patterns. 2018 DOJ Criminal Case Statistics: Typical Tax Criminal The analysis of the FY 2018 DOJ criminal case statistics reveals an interesting fact – a typical […]
CRS Success: 47 Million Financial Accounts Reported | FATCA Lawyer News
/in FATCA Lawyers, Legal Notes /by ManagerOn June 7, 2019, the Organization for Economic Cooperation and Development (“OECD”) announced that countries shared information concerning 47 million financial accounts under the OECD’s Common Reporting Standard (“CRS”). Let’s explore this CRS success in more detail. Measuring CRS Success: What is CRS? CRS can be called the response of the rest of the world […]
Hungarian Bank Accounts | US International Tax Lawyer & Attorney
/in international tax lawyer, Legal Notes /by ManagerUS taxpayers who own Hungarian bank accounts may have to comply with a large number of US tax reporting requirements. In particular, they need to be concerned about reporting income generated by their Hungarian bank accounts as well as disclosing the ownership of these accounts on FBAR and Form 8938. Other requirements may apply, but […]
2019 Third Quarter IRS Interest Rates | MN International Tax Law Firm
/in international tax lawyer, Legal Notes /by ManagerOn June 5, 2019, the Internal Revenue Service announced 2019 Third Quarter IRS Interest Rates. This quarter, the IRS interest rates will be reduced for the first time in years. 2019 Third Quarter IRS Interest Rates: 3rd Quarter and Interest Rates Defined Third quarter of 2019 begins on July 1, 2019 and ends on September […]
Minneapolis MN International Tax Lawyer & Attorney | PLR 201922010
/in international tax lawyer, Legal Notes /by ManagerOn May 31, 2019, the IRS released a Private Letter Ruling (“PLR”) on the extension of time to make an election to be treated as a disregarded entity for US tax purposes under Treas. Reg. Section 301.7701 (26 CFR 301.7701-3). Let’s explore this PLR 201922010 in more detail. PLR 201922010: Fact Pattern PLR 201922010 deals […]
IRC 965 Tax: Introduction | US International Tax Lawyer & Attorney
/in international tax lawyer, Legal Notes /by ManagerThe 2017 Tax Reform created the Internal Revenue Code Section 965, which requires US shareholders of foreign corporations to pay a new transition tax (hereinafter, “IRC 965 Tax”) in certain circumstances. In this short article, I will introduce the readers to the IRC 965 Tax. IRC 965 Tax: Taxpayers Who Are Targeted by the New […]
International Tax Lawyer & Attorney | April 2019 IRS Compliance Campaigns
/in International Tax Attorney Minnesota Minneapolis, Legal Notes /by ManagerOn April 16, 2019, the IRS Large Business and International division (LB&I) announced the approval of three additional compliance campaigns. Let’s discuss in more detail these April 2019 IRS compliance campaigns. April 2019 IRS Compliance Campaigns: Background Information In the mid-2010s, after extensive planning, the IRS decided to move LB&I toward issue-based examinations and a […]
Taylor Lohmeyer Law Firm Clients Face Potential IRS Audit | FBAR News
/in FBAR audit tax attorney, Legal Notes /by ManagerOn May 15, 2019, a Texas federal court ruled that the IRS can enforce a John Doe Summons for client information from Taylor Lohmeyer Law Firm because the firm failed to demonstrate that the attorney-client privilege protected this information. This is bad news for Taylor Lohmeyer Law Firm clients who now may have to face […]
Panamanian Bank Accounts | US International Tax Lawyer & Attorney
/in International Tax Attorney, Legal Notes /by ManagerA large number of US taxpayers own Panamanian bank accounts. These taxpayers have bank accounts in Panama for a variety of reasons: personal, business, tax planning and/or estate planning. Many of these account holders still do not realize that their Panamanian bank accounts may be subject to numerous reporting requirements in the United States. In […]