Tax Services

Sherayzen Law Office offers comprehensive tax services to our clients, concentrating on the toughest areas of U.S. tax law such as international tax compliance, IRS audits and complex tax planning for individuals and businesses. Our firm is also a one-stop US tax compliance center – we will process your entire case internally, including preparation of all legal documents and tax forms. The ability to cover the case from the beginning through the end, allows our experienced tax attorneys and accountants to approach the resolution of your case with unmatched creativity and diligence.

Most of our clients are upper-middle class and high-net-worth individuals, including professionals, college professors, entrepreneurs, investors, and small- and mid-size businesses located in the United States, Europe, Australia and Latin America. Oftentimes, our attorneys also deal with start-ups and non-profit organizations.

Our tax services may be grouped into four categories:

1. International Tax Compliance

Ability to provide efficient international tax compliance services in combination with creative professional solutions is one of the most unique aspects of Sherayzen Law Office.

In providing such services, our attorneys usually prepare the following tax forms: TD F 90-22.1 (FBAR – Report on Foreign Bank and Financial Accounts), foreign business entity ownership compliance (Forms 5471, 8865, 8858, 926 and related forms), foreign ownership of U.S. corporation (Form 5472 and related forms), foreign trust ownership (Form 3520), foreign gifts and inheritance (Form 3520), Canadian RRSP (Registered Retirement Savings Plans) and RRIF (Registered Retirement Income Funds) compliance (Form 8891), Passive Foreign Investment Company information returns (PFIC – Form 8621), FATCA compliance (Form 8938) and other related forms.

Representative Case: U.S. person living overseas owns a foreign corporation and several foreign partnerships with PFIC investments in Germany. Sherayzen Law Office attorneys prepared the client’s FBARs, Form 5471 for the foreign corporation, Forms 8865 for the partnerships and Forms 8621 for PFICs.

2. Offshore Voluntary Disclosures for Delinquent FBARs and Other Information Returns

This is our biggest tax compliance area. Every year, Sherayzen Law Office prepares, files and negotiates with the IRS a large number of Offshore Voluntary Disclosures for clients who live in the United States and overseas. Our experienced tax attorneys have dealt with IRS official voluntary disclosures as well as modified (a/k/a noisy or reasonable cause) voluntary disclosures, involving delinquent FBARs, foreign ownership forms (e.g. Forms 5471 and 8865), PFIC non-compliance, FATCA non-compliance. We have also had various clients in the 2011 OVDI (Offshore Voluntary Disclosure Initiative) and 2012 OVDP (Offshore Voluntary Disclosure Program).

Representative Case: Sherayzen Law Office successfully conducted voluntary disclosure for a dual citizen of the United States and Canada involving delinquent FBARs, unreported foreign rental income, unreported foreign taxes, non-compliant PFICs and non-compliant Form 5471 with respect to a foreign corporation.

3. IRS Audits including Audit Representation, Audit Reconsideration, Audit Appeals, and Tax Court Litigation

Whether you just received a notice from the IRS or you are in the middle of an IRS audit, Sherayzen Law Office can help. Our tax attorneys are rigorous advocates of your interests. We will thoroughly review your case, identify the relevant audit strategies with unmatched creativity, prepare all of the necessary tax forms and present the necessary legal arguments.

Representative Case: A corporation was subject to an IRS audit with respect to unfiled employment and income tax returns as well as unpaid employment and income taxes. At the outset, the business and its owner were not represented; the IRS expanded its review to five years, subjecting the business to extreme deadlines with the ultimate intention to dissolve the corporation and criminally charge its owner and officers. Sherayzen Law Office successfully represented the business and its owner, met all of the IRS deadlines, and prepared and filed all Forms 940/941 and 1120. During the final negotiation process, the corporation was preserved, the filing of criminal charges was avoided, the penalties were reduced and the IRS agreed to an installment payment plan.

4. Complex Tax Planning for Businesses and Individuals

Unmatched creativity combined with our tradition of detail-oriented ethical diligence gives Sherayzen Law Office a unique edge in the tax planning market. Sherayzen Law Office attorneys regularly engage in complex U.S. and international tax planning for businesses and high-net-worth individuals who reside in the United States and overseas. Our guiding principle in creating a comprehensive tax plan is to balance your ability to maximize the opportunities offered by the Internal Revenue Code (IRC) against the rising risk of IRS adverse decision – i.e. we strive to make sure that you do not overpay your taxes under the IRC provisions while minimize the risk of an IRS audit.

Representative Case: A Nevada corporation and a Nevada limited partnership owned by the same owners. Sherayzen Law Office attorneys were able to identify various tax return errors that resulted in gross over-payment of tax by the corporation and the owners. After the implementation of a comprehensive tax plan, the overall tax liability was reduced by more than 70% in the first year and further went down by about 15% in the second year.

As always, our main goal is to achieve the most satisfactory result for the client so that you and your business can find your own Legal Way Forward!

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