Report of Foreign Bank and Financial Accounts FINCEN Form 114

Atlanta FBAR Lawyer | FATCA International Tax Attorney

Can a lawyer who resides in Minneapolis be considered an Atlanta FBAR Lawyer? What kind of law should such a lawyer practice? These are the two questions that I seek to answer in this article.

Atlanta FBAR Lawyer Definition: Legal FBAR Services Provided in Atlanta, Georgia

Let’s start with the first question. The term Atlanta FBAR Lawyer is comprised of two broad category of lawyers. The first category consists of international tax lawyers who reside in Atlanta and offer FBAR services to the residents of Atlanta. This is self-explanatory.

The second category is a bit more complicated because it is comprised of international tax lawyers who reside outside of Atlanta but offer FBAR services to the residents of Atlanta. At first, this does not seem logical, but, once we look into the legal nature of the FBAR, it makes perfect sense.

FBAR is a federal information return required by Title 31 of the United State Code. This is not a local requirement of Atlanta or the State of Georgia; they have no influence over the interpretation and the implementation of the FBAR requirement. This means that any licensed US international tax lawyer can offer FBAR services in any of the 50 states and the District of Columbia irrespective of his physical location.

Now, it is clear why an Atlanta FBAR lawyer can reside in Minneapolis – since the local law has no influence over FBARs, there is no special knowledge or access to courts associated with local lawyers. In essence, a lawyer in Minneapolis can offer FBAR legal services in Atlanta with the same ease as a lawyer who resides in Atlanta.

Atlanta FBAR Lawyer Must Be a US International Tax Lawyer

Now, we can turn to second question of the relevant practice area of law. Since FBAR constitutes a small part of US international tax law, there is a profound connection between FBAR and international tax law. In fact, it is this relationship between the FBAR and the rest of the international tax law requirements that apply in a particular case (based on the facts of that case) that determines the legal position of the taxpayer in a voluntary disclosure case.

This means that an Atlanta FBAR lawyer must also be an international tax lawyer – i.e. a lawyer who has profound knowledge of US international tax law requirements, including FBAR.

Sherayzen Law Office Can Be Your Atlanta FBAR Lawyer

Sherayzen Law Office specializes in FBARs and the US international tax law. Our legal and accounting team has a profound knowledge of this area of law and the extensive experience in helping clients with international tax law issues, including offshore voluntary compliance with respect to delinquent FBARs. We have helped hundreds of US taxpayers worldwide with their FBAR issues and we can help You!

Contact Sherayzen Law Office today to schedule Your Confidential Consultation!

Seattle FBAR Lawyer | IRS FATCA International Tax Attorney

I recently received a phone call from a person who was looking for a Seattle FBAR lawyer online and found my website. He asked me whether I can help him even though Sherayzen Law Office is based in Minneapolis, Minnesota. I responded to him: “yes, I can help you”.

This conversation brought to light an important topic of who should be considered a Seattle FBAR Lawyer and why an international tax lawyer based in Minneapolis can help a client in Seattle with FBAR issues.

Seattle FBAR Lawyer Definition: Legal FBAR Services Provided in Seattle, Washington

There are two categories of lawyers that fit the term Seattle FBAR Lawyer. The first category consists of US international tax lawyers who reside in Seattle and offer FBAR services to the residents of Seattle. The second category is comprised of US international tax lawyers who reside outside of Seattle but offer FBAR services to the residents of Seattle.

The first category is clear – if a lawyer resides in Seattle and offers FBAR services, he is considered to be a Seattle FBAR Lawyer. The question is: why is a lawyer who resides outside of Seattle still considered a Seattle FBAR lawyer? The answer lies in the legal nature of FBARs. FBAR is a federal information return, not a local requirement of Seattle or the State of Washington. This means that any licensed US international tax lawyer can offer FBAR services in any of the 50 states and the District of Columbia irrespective of his physical location. This is why a lawyer who resides in Minneapolis can offer FBAR legal services in Seattle with the same ease as a lawyer who resides in Seattle.

Seattle FBAR Lawyer Must Be US International Tax Lawyer

It should be emphasized that, while the residence of a Seattle FBAR Lawyer is not relevant, his area of practice is highly important. A Seattle FBAR lawyer must be an international tax lawyer – i.e. a lawyer who not only knows how to complete FBARS, but who has profound knowledge of US international tax law and the place the FBARs occupy in this law.

This emphasis is based on the fact that FBAR is only a small part of a much larger area of US international tax law. Indeed, there is a deep and complex relationship between the FBAR and international tax law that determines the legal position of a client and the potential voluntary disclosure strategies associated with delinquent FBARs.

This is why your Seattle FBAR lawyer should have deep knowledge of and extensive experience in both FBARs and all related US international tax laws and regulations.

Sherayzen Law Office Can Be Your Seattle FBAR Lawyer

Sherayzen Law Office is an international tax law firm that specializes in FBARs and international tax law. Our legal and accounting team has both: a profound knowledge of this area of law and extensive experience in helping clients with international tax law issues, including offshore voluntary compliance with respect to delinquent FBARs. We have helped hundreds of US taxpayers worldwide with their FBAR issues and we can help You!

Contact Sherayzen Law Office today to schedule Your Confidential Consultation!

What to do if the IRS Audits Your Quiet Disclosure | FBAR Lawyer Madison

This essay is concerned with a situation where the IRS audits your quiet disclosure of foreign assets and foreign income. The IRS audit can be an absolute nightmare in this case. Not only will the audit examine the accuracy of the disclosure, but the IRS may actually raise the issue of willful and non-willful FBAR penalties as well as the potential income tax fraud penalty.

So, is everything lost if the IRS audits your quiet disclosure? The answer is “no”. While the situation may undoubtedly be dire, it is not hopeless if the case is handled properly. While it is not possible to discuss in this article the whole spectrum of strategies available to taxpayers in such a situation, this article attempts to line out the three most important steps that you should do if the IRS audits your quiet disclosure.

1. If the IRS Audits Your Quiet Disclosure, You Should Not Panic

An IRS audit is always a stressful event. The stress increases exponentially if the audit involves a quiet disclosure of foreign assets and foreign income.

While your situation may be difficult, you should try to resist the panic. Panic is an emotional condition where a person starts acting irrationally and may follow a course of action that may worsen the already difficult situation.

2. If the IRS Audits Your Quiet Disclosure, Do Not Try to Handle the Audit by Yourself

Do NOT attempt to solve the IRS audit of your quiet disclosure by yourself, even if you believe that you were non-willful in your original noncompliance. This is extremely dangerous and may result in imposition of non-willful or even willful penalties. US international tax law is so complex that you may easily get yourself in trouble even if you believe that you are doing well.

There is a myth that the IRS is somehow gracious when a taxpayer represents himself and will be willing to reduce the penalties – this is completely false, especially in a situation involving a quiet disclosure. The IRS agents follow procedures and they will follow them ruthlessly until they run into a legal defense built by a lawyer. Without such a defense, there is nothing to stop the IRS from imposing penalties to the extent an agent believes is justified by the facts of the case.

3. If the IRS Audits Your Quiet Disclosure, You Should Immediately Find and Retain an International Tax Lawyer

Get yourself an international tax lawyer to help you with an IRS audit of your quiet disclosure. This can be a highly complex situation and you should have a professional by your side to guide you throughout the process. This is the best way to assure that your case will be handled properly.

In this case, a professional must be an international tax lawyer, not an accountant. I am always suspicious of cases where accountants start to go beyond their professional capacity and take on the legal defense of their clients’ cases. While it may be tolerable in simple domestic cases (though still not recommended), it may result in a horrific outcome where the IRS audits a quiet disclosure.

Sherayzen Law Office Can Be Your International Tax Lawyer if the IRS Audits Your Quiet Disclosure

If the IRS audits your quiet disclosure, consider retaining Sherayzen Law Office, Ltd. as your international tax lawyer to represent you during the IRS audit. Sherayzen Law Office is an international tax firm which focuses on helping its clients with their voluntary disclosures and the audits of these voluntary disclosures. The firm is not only a leader in the field, but it has also extensive experience in combating and reducing the IRS penalties associated with prior tax noncompliance.

Milwaukee FBAR Lawyer | IRS FATCA Tax Attorney

Who is considered to be a Milwaukee FBAR Lawyer? This is a question that is important to all residents of Milwaukee, Wisconsin. Let me try to answer this question.

Milwaukee FBAR Lawyer Definition: Legal FBAR Services Provided in Milwaukee, Wisconsin

The term Milwaukee FBAR Lawyer includes two broad categories of international tax lawyers. The first category consists of lawyers who reside in Milwaukee and offer FBAR services to the residents of Milwaukee. The second category is comprised of lawyers who reside outside of Milwaukee but offer FBAR services to the residents of Milwaukee.

The first category is self-explanatory, but the second category requires a bit more explanation of one issue: why is an FBAR lawyer who resides outside of Milwaukee still considered a Milwaukee FBAR lawyer? The answer is relatively simple – FBAR is a federal compliance requirement and any licensed US international tax lawyer can practice it in any of the 50 states and the District of Columbia irrespective of his physical location. Local Milwaukee law and even Wisconsin law have nothing to do with FBARs.

A Milwaukee FBAR Lawyer Must be an International Tax Lawyer

I mentioned above that both categories of the definition of a Milwaukee FBAR Lawyer must consist of only international tax lawyers. I wish to emphasize this point – not any lawyer should advise with respect to FBARs, only US international tax lawyers.

This emphasis on knowledge of the US international tax law is not incidental; it is based on the fact that FBAR is merely a part of a much bigger US international tax law. These concepts are so deeply interrelated that it would be nonsensical to advise a client on his legal position just on the FBARs without the related US international tax law issues or the US international tax law without the FBARs.

This is why your Milwaukee FBAR lawyer should have a profound knowledge of and experience in both FBARs and all related US international tax laws and regulations.

Sherayzen Law Office is a Premier International Firm Well-Positioned to be Your Milwaukee FBAR Lawyer

Sherayzen Law Office is the perfect candidate to be Your Milwaukee FBAR Lawyer. Not only does its team has a profound knowledge of FBARs and US international tax law, but its professional legal team is also highly experienced in dealing with these issues, including all Offshore Voluntary Compliance programs related to delinquent FBARs. We have helped hundreds of US taxpayers worldwide with their FBAR issues and we can help You!

Contact Sherayzen Law Office today to schedule Your Confidential Consultation!