2019 FBAR Conversion Rates | FBAR Tax Lawyer & Attorney

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 the default choice, not an exclusive one). In other words, the 2019 FBAR conversion rates are used to translate foreign-currency highest balances into US dollars for the purposes of FBAR and Form 8938 compliance.

The U.S. Department of Treasury  already published the 2019 FBAR conversion rates online (they are called “Treasury’s Financial Management Service rates” or the “FMS rates”).

Since the 2019 FBAR conversion rates are highly important to US taxpayers, international tax lawyers and international tax accountants, Sherayzen Law Office provides the table below listing the official 2019 FBAR conversion rates (note that the readers still need to refer to the official website for any updates).

Country – Currency Foreign Currency to $1.00
AFGHANISTAN – AFGHANI77.6250
ALBANIA – LEK108.2100
ALGERIA – DINAR118.7800
ANGOLA – KWANZA475.0000
ANTIGUA – BARBUDA – E. CARIBBEAN DOLLAR2.7000
ARGENTINA – PESO59.8700
ARMENIA – DRAM475.0000
AUSTRALIA – DOLLAR1.4250
AUSTRIA – EURO0.8900
AZERBAIJAN – NEW MANAT1.7000
BAHAMAS – DOLLAR1.0000
BAHRAIN – DINAR0.3770
BANGLADESH – TAKA85.0000
BARBADOS – DOLLAR2.0200
BELARUS – NEW RUBLE2.1040
BELGIUM – EURO0.8900
BELIZE – DOLLAR2.0000
BENIN – CFA FRANC582.0000
BERMUDA – DOLLAR1.0000
BOLIVIA – BOLIVIANO6.8300
BOSNIA – MARKA1.7410
BOTSWANA – PULA10.5490
BRAZIL – REAL4.0200
BRUNEI – DOLLAR1.3450
BULGARIA – LEV1.7410
BURKINA FASO – CFA FRANC582.0000
BURMA-KYAT1,475.0000
BURUNDI – FRANC1,850.0000
CAMBODIA (KHMER) – RIEL4,051.0000
CAMEROON – CFA FRANC578.1200
CANADA – DOLLAR1.3000
CAPE VERDE – ESCUDO99.2910
CAYMAN ISLANDS – DOLLAR0.8200
CENTRAL AFRICAN REPUBLIC – CFA FRANC578.1200
CHAD – CFA FRANC578.1200
CHILE – PESO751.4800
CHINA – RENMINBI6.9610
COLOMBIA – PESO3,278.7500
COMOROS – FRANC439.0600
CONGO – CFA FRANC578.1200
COSTA RICA – COLON569.6500
COTE D’IVOIRE – CFA FRANC582.0000
CROATIA – KUNA6.4900
CUBA – Chavito1.0000
CYPRUS – EURO0.8900
CZECH REPUBLIC – KORUNA22.1650
DEM. REP. OF CONGO – FRANC1,650.0000
DENMARK – KRONE6.6520
DJIBOUTI – FRANC177.0000
DOMINICAN REPUBLIC – PESO52.6600
ECUADOR – DOLARES1.0000
EGYPT – POUND16.0000
EL SALVADOR – DOLARES1.0000
EQUATORIAL GUINEA – CFA FRANC578.1200
ERITREA – NAKFA15.0000
ESTONIA – EURO0.8900
ETHIOPIA – BIRR31.8000
EURO ZONE – EURO0.8900
FIJI – DOLLAR2.1420
FINLAND – EURO0.8900
FRANCE – EURO0.8900
GABON – CFA FRANC578.1200
GAMBIA – DALASI51.0000
GEORGIA – LARI2.8700
GERMANY – EURO0.8900
GHANA – CEDI5.6600
GREECE – EURO0.8900
GRENADA – EAST CARIBBEAN DOLLAR2.7000
GUATEMALA – QUENTZAL7.6900
GUINEA BISSAU – CFA FRANC582.0000
GUINEA – FRANC9,380.0000
GUYANA – DOLLAR215.0000
HAITI – GOURDE87.6550
HONDURAS – LEMPIRA25.0000
HONG KONG – DOLLAR7.7860
HUNGARY – FORINT294.2900
ICELAND – KRONA120.7600
INDIA – RUPEE71.0000
INDONESIA – RUPIAH13,895.0000
IRAN – RIAL42,000.0000
IRAQ – DINAR1,138.0000
IRELAND – EURO0.8900
ISRAEL – SHEKEL3.4540
ITALY – EURO0.8900
JAMAICA – DOLLAR136.0000
JAPAN – YEN108.5300
JERUSALEM – SHEKEL3.4540
JORDAN – DINAR0.7080
KAZAKHSTAN – TENGE381.1800
KENYA – SHILLING101.2500
KOREA – WON1,153.7000
KOSOVO – EURO0.8900
KUWAIT – DINAR0.3030
KYRGYZSTAN – SOM69.6000
LAOS – KIP8,865.0000
LATVIA – EURO0.8900
LEBANON – POUND1500.0000
LESOTHO – MALOTI14.0560
LIBERIA – DOLLAR186.9900
LIBYA – DINAR1.3960
LITHUANIA – EURO0.8900
LUXEMBOURG – EURO0.8900
MADAGASCAR – ARIARY3,627.2000
MALAWI – KWACHA760.0000
MALAYSIA – RINGGIT4.0890
MALDIVES – RUFIYAA15.4200
MALI – CFA FRANC582.0000
MALTA – EURO0.8900
MARSHALL ISLANDS – DOLLAR1.0000
MARTINIQUE – EURO0.8900
MAURITANIA – OUGUIYA37.0000
MAURITIUS – RUPEE36.2000
MEXICO – PESO18.8920
MICRONESIA – DOLLAR1.0000
MOLDOVA – LEU17.1000
MONGOLIA – TUGRIK2,733.5200
MONTENEGRO – EURO0.8900
MOROCCO – DIRHAM9.5970
MOZAMBIQUE – METICAL 60.8500
NAMIBIA – DOLLAR14.0560
NEPAL – RUPEE113.7500
NETHERLANDS – EURO0.8900
NETHERLANDS ANTILLES – GUILDER1.7800
NEW ZEALAND – DOLLAR1.4830
NICARAGUA – CORDOBA33.8000
NIGER – CFA FRANC582.0000
NIGERIA – NAIRA361.0000
NORWAY – KRONE8.7820
OMAN – RIAL0.3850
PAKISTAN – RUPEE154.8500
PANAMA – BALBOA1.0000
PANAMA – DOLARES1.0000
PAPUA NEW GUINEA – KINA3.3110
PARAGUAY – GUARANI6,442.3301
PERU – SOL3.3140
PHILIPPINES – PESO50.6400
POLAND – ZLOTY3.7890
PORTUGAL – EURO0.8900
QATAR – RIYAL3.6400
REP. OF N MACEDONIA – DINAR54.7600
REPUBLIC OF PALAU – DOLLAR1.0000
ROMANIA – NEW LEU4.2560
RUSSIA – RUBLE62.2730
RWANDA – FRANC925.0000
SAO TOME & PRINCIPE – NEW DOBRAS22.1220
SAUDI ARABIA – RIYAL3.7500
SENEGAL – CFA FRANC582.0000
SERBIA – DINAR104.9200
SEYCHELLES – RUPEE13.6200
SIERRA LEONE – LEONE9,639.5898
SINGAPORE – DOLLAR1.3450
SLOVAK REPUBLIC – EURO0.8900
SLOVENIA – EURO0.8900
SOLOMON ISLANDS – DOLLAR8.0650
SOMALI – SHILLING575.0000
SOUTH AFRICA – RAND14.0560
SOUTH SUDANESE – POUND160.0000
SPAIN – EURO0.8900
SRI LANKA – RUPEE181.3000
ST LUCIA – E CARIBBEAN DOLLAR2.7000
SUDAN – SUDANESE POUND45.0000
SURINAME – GUILDER7.5200
SWAZILAND – LANGENI14.0560
SWEDEN – KRONA9.3010
SWITZERLAND – FRANC0.9660
SYRIA – POUND435.0000
TAIWAN – DOLLAR29.9420
TAJIKISTAN – SOMONI9.6500
TANZANIA – SHILLING2,293.0000
THAILAND – BAHT29.7700
TIMOR – LESTE DILI1.0000
TOGO – CFA FRANC582.0000
TONGA – PA’ANGA2.2090
TRINIDAD & TOBAGO – DOLLAR6.6970
TUNISIA – DINAR2.7720
TURKEY – LIRA5.9420
TURKMENISTAN – NEW MANAT3.4910
UGANDA – SHILLING3,660.0000
UKRAINE – HRYVNIA23.6900
UNITED ARAB EMIRATES – DIRHAM3.6730
UNITED KINGDOM – POUND STERLING0.7580
URUGUAY – PESO37.1300
UZBEKISTAN – SOM9,500.0000
VANUATU – VATU112.8000
VENEZUELA – BOLIVAR SOBERANO70,675.7400
VENEZUELA – FUERTE (OLD)248,832.0000
VIETNAM – DONG23,171.0000
WESTERN SAMOA – TALA2.5370
YEMEN – RIAL480.0000
ZAMBIA – NEW KWACHA14.0500
ZIMBABWE – RTGS16.2800

2020 Streamlined Domestic Offshore Procedures: Pros and Cons

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 readers to better understand why I make this assertion, I would like to discuss the advantages and disadvantages of participating in the 2020 Streamlined Domestic Offshore Procedures.

2020 Streamlined Domestic Offshore Procedures: Background Information and Purpose

The IRS created the Streamlined Domestic Offshore Procedures (sometimes abbreviated as “SDOP”) on June 18, 2014, though the Certification forms became available only a few months later. Since its introduction, Streamlined Domestic Offshore Procedures quickly eclipsed the then-existing IRS Offshore Voluntary Disclosure Program (“OVDP”) and became the most popular offshore voluntary disclosure option.

The main purpose of the Streamlined Domestic Offshore Procedures is to encourage noncompliant US taxpayers to voluntarily resolve their prior non-willful noncompliance with US international tax compliance requirements. These requirements include all US international information returns such as FBAR, Form 8938, Form 5471, Form 8621, Form 3520, Form 926, et cetera.

2020 Streamlined Domestic Offshore Procedures: Main Advantages

In exchange for this voluntary disclosure of their prior tax noncompliance, US taxpayers escape income tax penalties and pay only a one-time Miscellaneous Offshore Penalty with respect to their prior failures to file the required US international information returns. The Miscellaneous Offshore Penalty is usually far below the potential penalties normally associated with failure to file these forms. In other words, noncompliant taxpayers can greatly reduce their IRS noncompliance penalties through their participation in the Streamlined Domestic Offshore Procedures. This is one of the most important SDOP benefits.

Another advantage of the Streamlined Domestic Offshore Procedures is the limited scope of this voluntary disclosure option. Taxpayers only need to file a small number of amended US tax returns (usually three) and FBARs (usually six) – in other words, the filings are limited to regular statute of limitations without any expansions (as opposed to OVDP which required filings for the past eight years).

Moreover, despite the limited scope of the SDOP filings, taxpayers who utilize the Streamlined Domestic Offshore Procedures are able to fully resolve their prior US international tax noncompliance issues even if these years are not included in the actual SDOP filings. This means that the participating taxpayers are able “wipe the slate clean” – i.e. to erase their prior US international tax noncompliance from the time when it began.

The last major advantage of the Streamlined Domestic Offshore Procedures is that this option only requires to establish non-willfulness rather than reasonable cause. Non-willfulness is a much easier legal standard to satisfy (be careful, I am not saying that this is an “easy standard”, just an easier one) than reasonable cause.

2020 Streamlined Domestic Offshore Procedures: Main Disadvantages

For the purpose of this article, I will discuss only two major disadvantages to the Streamlined Domestic Offshore Procedures. First, the eligibility requirements are strict. This voluntary disclosure option is open only to taxpayers who filed their US tax returns for prior years and who are able to certify under the penalty of perjury that their prior noncompliance was non-willful. This certification has to be made specifically with respect to unreported foreign income, FBARs and each other international information return.

Most cases have positive and negative facts at the same time. Hence, a lot of taxpayers are actually in the “gray” area between willfulness and non-willfulness. This means that it is not easy to make a decision on whether a taxpayer is eligible to participate in the Streamlined Domestic Offshore Procedures. This decision should be done only by an experienced international tax attorney who specializes in this area of law, such as Mr. Eugene Sherayzen of Sherayzen Law Office.

The second major disadvantage of the Streamlined Domestic Offshore Procedures is lack of a definitive closure; there may be a follow-up audit after the IRS processes your voluntary disclosure package Unlike OVDP, Streamlined Domestic Offshore Procedures does not offer a Closing Agreement without an audit. This means that going through Streamlined Domestic Offshore Procedures may not be the end of your case; the IRS can actually audit you over the next three years. If this happens, the audit of your voluntary disclosure will focus not only on the correctness of your disclosure, but also on the truthfulness and correctness of your non-willfulness certification.

Contact Sherayzen Law Office for Professional Help With 2020 Streamlined Domestic Offshore Procedures

If you have undisclosed foreign accounts or any other foreign assets, contact Sherayzen Law Office for professional help with your offshore voluntary disclosure. We have successfully helped hundreds of US taxpayers around the world with their offshore voluntary disclosures, including Streamlined Domestic Offshore Procedures. We can also help you!

Contact Us Today to Schedule Your Confidential Consultation!

IRC §318 Family Attribution | International Tax Law Firm Minnesota

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 constructive owner of shares owned (directly and indirectly) by his spouse, children, grandchildren and parents. While it appears to be simple, this general rule has a number of exceptions and complications.

§318 Family Attribution: Certain Exceptions for Spouses

Under §318(a)(1)(A)(i), ownership of stock held by a spouse who is legally separated under a decree of divorce or separate maintenance is not attributed to her spouse. However, based on the §318 legislative history and Commissioner v. Ostler, 237 F.2d 501 (9th Cir. 1956), it appears that an interlocutory decree of divorce would not prevent the attribution of stock ownership between spouses, because such decree is not final.

§318 Family Attribution: Special Cases Involving Children and Grandchildren

§318(a)(1)(B) expands the attribution of shares from children to shares held by legally adopted children. Without legal adoption, however, shares owned by a step-child cannot be attributed to step-parents and step-grandparents. Similarly, absent legal adoption of a step-child, there is no attribution from a step-parent to the step-child.

Treas. Reg. §1.318-2(b) also makes it clear that there is no attribution of shares owned by grandparents to their grandchildren. Only shares owned by grandchildren can be attributed to their grandparents. For example, if a grandfather and a grandson each own 100 shares of X, a C-corporation, the grandfather will be deemed to own 200 shares while the grandson’s stock ownership will be based only on his actual ownership of 100 shares.

Also, note that great-grandchildren are not listed under §318(a)(1). Hence, the shares owned by great-grandchildren are not attributed to great-grandparents; this is different from §267.

§318 Family Attribution: Other Relatives

The §318 definition of family excludes aunts, uncles, nieces, nephews and cousins; this treatment is identical to that of §267. Moreover, unlike §267(c)(4), there is no attribution of stock between siblings under §318(a)(1).

§318 Family Attribution: Prohibition of Double Attribution

Treas. Reg. §1.318-4(b) explains that §318 family attribution rules do not allow double attribution of stock among family members. Under §318(a)(5)(B), stock deemed owned through a family member under §318(a)(1)(A) may not be re-attributed to another family member under the family attribution rules of §318.

For example, let’s say that mother M, daughter D and son S each own one-third of the outstanding shares of X corporation; each of them owns 100 shares. Under §318(a)(1)(A), M owns 100 shares and is deemed to own her children’s 200 shares. On the other hand, D actually owns 100 shares and is deemed to own her mother’s 100 shares – i.e. 200 shares total; under §318(a)(5)(B), while M is deemed to own 100 of S, there is no re-attribution of S’ 100 shares to D. In other words, §318(a)(5)(B) prevents the attribution of brother’s stock to his sister through the deemed ownership of brother’s stock by their mother. Also, as explained above, there is no family attribution of stocks between siblings.

§318 Family Attribution: Special Rule Concerning §302(c)(2)

IRC §302(c)(2) relates to redemptions of corporate stock and contains a special rule concerning the waiver of §318 family attribution of stocks. This section permits the termination of attribution of stock from family members when a shareholder severs ties with the corporation. The purpose of this rule is to allow such shareholder report capital gains instead of dividends upon the redemption of corporate stock.

§318 Family Attribution: Multiple Control of Corporation Possible

The upshot of the §318 rules is the expansion of stock ownership to an extent where multiple related parties may be deemed to be in control of a corporation (and even be deemed as owners of all shares of the corporation) at the same time.

For example, let’s suppose that there are five family members: husband (H), wife (W), son (S), H’s mother (i.e. grandmother – M) and son of S (i.e. grandson – G). Each of them actually owns 100 shares of corporation Y; there are 500 shares outstanding in total. Let’s analyze each of these person’s actual and constructive ownership of shares under the §318 family attribution rules.

H owns all 500 shares under the §318 family attribution rules. He actually owns 100 shares; the rest of the shares are attributed to him from his mother, his wife, son and grandson.

W owns 400 shares under the §318 family attribution rules. She actually owns 100 shares and constructively owns 300 shares that belong to her husband, son and grandson. However, she does not own 100 shares owned by her mother-in-law and the re-attribution of ownership of these shares through her husband is prevented by §318(a)(5)(B).

M owns 300 shares under the §318 family attribution rules. She actually owns 100 shares and is deemed to own 100 shares owned by her son and 100 shares owned by her grandson. M, however, is not deemed to own stocks held by her daughter-in-law W and her great-grandson G.

S owns 400 shares under the §318 family attribution rules. He actually owns 100 shares and constructively owns 200 shares owned by his parents and 100 shares owned by his son. S, however, does not constructively own shares held by his grandmother.

Finally, G owns 200 shares under the §318 family attribution rules. He actually owns 100 shares and constructively owns 100 shares held by his father S. G, however, does not constructively own shares held by his grandparents H and M as well as his great-grandmother M.

Thus, even though each family member actually owns only 100 shares, four of them (out of the total five) are deemed to be in control of the corporation and H is deemed to own the entire corporation. If we transfer this scenario to US international tax law, we can immediately see that the application of §318 constructive ownership rules through family attribution may greatly increase the tax compliance burden for this family.

Contact Sherayzen Law Office for Professional Help With US International Tax Law

IRC §318 is but a tiny part of the incredible voluminous US domestic and international tax law. US international tax law is not only very complex, but it is also very severe with respect to noncompliant taxpayers. In other words, it is very easy to get yourself into trouble with respect to US international tax compliance and, once this happens, you may be subject to high IRS penalties.

In order to avoid such an undesirable result, you need the help of Sherayzen Law Office. We are a highly-experienced US international tax law firm that has helped clients from over 70 countries with their US international tax compliance. We can help you!

Contact Us Today to Schedule Your Confidential Consultation!

2020 Offshore Voluntary Disclosure Options | US International Tax Lawyers

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 options available to US taxpayers who wish to reduce their IRS penalties by voluntarily resolving their prior US tax noncompliance concerning foreign assets and foreign income.

2020 Offshore Voluntary Disclosure Options: Streamlined Domestic Offshore Procedures

The Streamlined Domestic Offshore Procedures (“SDOP”) is currently the flagship voluntary disclosure option for US taxpayers who reside in the United States. SDOP is a highly beneficial voluntary disclosure option to non-willful taxpayers: it is simple, limited (in terms of the voluntary disclosure period for which tax returns and FBARs must be filed) and mild (in terms of its penalty structure). There are some drawbacks to SDOP, such as the imposition of the Miscellaneous Offshore Penalty on income-tax compliant foreign accounts, but the benefits offered by this option outweigh its deficiencies for most taxpayers.

The main challenge of SDOP is its requirement that a taxpayer certifies under the penalty of perjury that he was non-willful with respect to his prior income tax noncompliance, FBAR noncompliance and noncompliance with any other US international information tax return (such as Form 8938, 3520, 5471, et cetera). This is a huge problem for willful taxpayers and taxpayers who are in the “gray” area between willfulness and non-willfulness. It will be up to your international tax lawyer to make the determination on whether you are able to make this certification.

2020 Offshore Voluntary Disclosure Options: Streamlined Foreign Offshore Procedures

Streamlined Foreign Offshore Procedures (“SFOP”) is very similar to SDOP (in fact, both options were created in 2014), but it is even more beneficial to taxpayers who are able to satisfy SFOP’s eligibility requirements – this is a true amnesty program, because its participants do not pay IRS penalties of any kind, even on income tax due (taxpayers only need to pay the interest on additional tax due). Moreover, SFOP preserves SDOP’s non-invasive and limited scope of voluntary disclosure.

SFOP, however, is available to a much more limited number of US taxpayers who are able to satisfy its eligibility requirements, particularly those related to non-willfulness certification and physical presence outside of the United States. Again, you should contact Sherayzen Law Office to help you determine whether you meet the eligibility requirements of SFOP.

2020 Offshore Voluntary Disclosure Options: Delinquent FBAR Submission Procedures

Delinquent FBAR Submission Procedures (“DFSP”) is another voluntary disclosure option that fully eliminates IRS penalties. This is not a new option; in fact, in one form or another, it has always existed within the IRS procedures. Prior to 2014, it was even written into the OVDP (IRS Offshore Voluntary Disclosure Program) as FAQ#17.

While DFSP is highly beneficial to noncompliant US taxpayers, it is available to even fewer number of taxpayers than those who are eligible for SDOP and SFOP. This is the case due to two factors. First, DFSP has a very narrow scope – it applies only to FBARs. Second, DFSP has extremely strict eligibility requirements; even de minimis income tax noncompliance will deprive a taxpayer of the ability to use this option.

2020 Offshore Voluntary Disclosure Options: Delinquent International Information Return Submission Procedures

Delinquent International Information Return Submission Procedures (“DIIRSP”) has a very similar history to DFSP. In fact, it was “codified” into OVDP rules as FAQ#18. Similarly to DFSP, DIIRSP also offers the possibility of escaping IRS Penalties. DIIRSP has a broader scope than DFSP and applies to international information returns other than FBAR, such as Form 8938, 3520, 5471, 8865, 926, et cetera.

Since it turned into an independent voluntary disclosure option in 2014, DIIRSP’s eligibility requirements became much harsher. US taxpayers are now required to provide a reasonable cause explanation in order to escape IRS penalties under this option. On the other hand, the fact that there may be unreported income associated with international information returns is not an impediment by itself to participation in DIIRSP.

2020 Offshore Voluntary Disclosure Options: Modified IRS Traditional Voluntary Disclosure Program

The traditional IRS Offshore Voluntary Disclosure Program (“TVDP”) has existed for a very long time. However, it faded into a complete obscurity once the IRS opened its first major OVDP option in 2009. The closure of 2014 OVDP in September of 2018 has brought TVDP back to life, but in a modified format.

On November 20, 2018, the IRS has completely revamped the TVDP’s procedural structure and clarified the penalty imposition rules. I am almost tempted to call this new version of TVDP as “2018 TVDP”!

The main benefit of TVDP is that it is now the main voluntary disclosure option for taxpayers who willfully violated their US tax obligations. If you are willful taxpayer, contact Sherayzen Law Office to explore your voluntary disclosure option under the TVDP.

2020 Offshore Voluntary Disclosure Options: Reasonable Cause Disclosure

Since 2014, the popularity of Reasonable Cause disclosure (also known as “Noisy Disclosure”) has declined substantially due to the introduction of SDOP and SFOP. Nevertheless, Reasonable Cause disclosure continues to be a highly important voluntary disclosure alternative to official IRS voluntary disclosure options. In fact, the closure of the 2014 OVDP in September of 2018 has led to some resurgence of Reasonable Cause disclosures.

Reasonable Cause disclosure is based on the actual statutory language; it is not part of any official IRS program. Special care must be taken in using this option, because this is a high-risk, high-reward option. If a taxpayer is able to satisfy his high burden of proof, then, he will be able to avoid IRS penalties. If the IRS audits the Reasonable Cause disclosure and disagrees, this taxpayer may face significant IRS penalties and, potentially, years of IRS litigation.

Contact Sherayzen Law Office for Professional Analysis of Your 2020 Offshore Voluntary Disclosure Options

If you have undisclosed foreign assets, contact Sherayzen Law Office for professional help as soon as possible. We have successfully helped hundreds of US taxpayers from over 70 countries with their voluntary disclosures of foreign assets to the IRS, and we can help you!

Contact Us Today to Schedule Your Confidential Consultation!

2019 Tax Filing Season for Individual Filers Opens on January 27 2020

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 taxes owed is April 15, 2020. The IRS expects that individual taxpayers will file more than 150 million tax returns for the tax year 2019; the vast majority of them should come in prior to the April deadline.

This is not the case, however, for US taxpayers with exposure to international tax requirements. Usually, most of these taxpayers file extensions in order to properly prepare all of the required international information returns by the extended deadline in October. Often, such tax filing extensions are necessary in order to obtain the necessary information from foreign countries which may operate on a fiscal year rather than a calendar year. However, even in such cases, taxpayers are expected to pay at least 90% of the tax owed by April 15, 2020.

Moreover, it should be mentioned that taxpayers who reside overseas receive an automatic tax filing extension. For such taxpayers, the 2019 tax filing season will commence also on January 27, 2020, but their tax return filing deadline is June 15, 2020.

The IRS is certain that it will be ready for the 2019 tax filing season by January 27, 2020. In other words, the agency believes that it will not only be able to process the returns smoothly, but all of its security systems will be operational by that date. The IRS also believes that, by January 27, 2020, it will address the potential impact of recent tax legislation on 2019 tax returns

The IRS encourages everyone to e-file their 2019 tax returns. This, however, is not always possible for US taxpayers who have to file international information returns due to software limitations.

Contact Sherayzen Law Office for Professional Help With Your 2019 Tax Filing Season If You Have To Comply With US International Tax Filing Requirements

Sherayzen Law Office helps US and foreign persons with their US international tax compliance requirements, including the filing of all required international information returns such as FBAR, FATCA Form 8938, Form 3520, Form 3520-A, Form 5471, Form 8865, Form 8858, Form 926 and other relevant forms.

With respect to taxpayers who have not been in full compliance with these requirements in the past, Sherayzen Law Office helps you to choose, prepare and file the relevant offshore voluntary disclosure option, including Streamlined Domestic Offshore Procedures, Streamlined Foreign Offshore Procedures, Delinquent International Information Return Submission Procedures, Delinquent FBAR Submission Procedures, Reasonable Cause Noisy Disclosures and Modified IRS Traditional Voluntary Disclosures.

Contact Us Today to Schedule Your Confidential Consultation!