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FATCA Lawyer: Connection Between UBS Case and FATCA

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Hello, and welcome to Sherayzen Law Office video blog; my name is Eugene Sherayzen and I’m an international Tax Attorney and owner of Sherayzen Law Office, Ltd.

Today, we are continuing our blog from Zurich, Switzerland and as you can see, we have UBS in the background; this is the UBS headquarters (in Switzerland). What I would like to talk about today, is what happened after UBS caved in to the IRS demands to turn over the names of US taxpayers who own accounts at UBS.

This happened in 2008. What happened next is quite remarkable. Basically, once one of the largest Swiss banks admitted that it can be bullied into submission by the IRS, the rest of the banks started to follow suit. The influence of the US Government grew enormously from that point on. The next thing that happened after the UBS defeat was the creation of the 2009 Offshore Voluntary Disclosure Program or OVDP. During the program, which was extremely successful, the IRS has collected an enormous amount of information about Swiss banks sufficient for it to make the next step and the next step was the enactment of FATCA.

FATCA is a huge topic. Let’s just say that FATCA revolutionized the entire legal landscape of International Tax Compliance. FATCA pretty much put an end to unlimited bank secrecy that existed prior to the 2008 UBS case. Next time, we will discuss more of what FATCA meant for International Tax Compliance and then we’ll also talk about the 2011 OVDI Program and the 2012 OVDP with it’s successor, the 2014 OVDP Program (now closed).

Thank you for watching, until the next time.

US Tax Reporting of Foreign Investment Accounts | FBAR Lawyer

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Hello, and welcome to Sherayzen Law Office video blog; my name is Eugene Sherayzen and I’m an international Tax Attorney and owner of Sherayzen Law Office, Ltd.

Today, we’re continuing our series of blogs from Zurich, Switzerland and in fact, we are standing in front of Swissquote. This is the company that trades Swiss stocks and the reason why it’s important is because there are still a lot of taxpayers with Swiss stocks who do not realize that even if they disclose their Foreign Bank Accounts, they also have to disclose their Foreign Stock Trading Accounts and Foreign Mutual Funds. All of this has to be disclosed to the IRS.

Now, how do you disclose it? There are two main forms that you need to worry about: FBAR, the Foreign Bank and Financial Accounts Report or Form 8938 which is attached to your tax return. Also, if you are investing in Foreign Mutual Funds, e.g. Swiss Mutual Funds through Swissquote, you also need to disclose them on Form 8621, which is quite complex.

If you would like to learn more about what you need to do in order to stay in US Tax Compliance, with respect to your Foreign Investment Accounts, you can contact me directly at (952) 500-8159 or you can email me at [email protected].

Thank you for watching, until the next time.

Foreign Accounts & US Tax Residency | International Tax Lawyer United States

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Hello, and welcome to Sherayzen Law Office video blog; my name is Eugene Sherayzen and I’m an international Tax Attorney and owner of Sherayzen Law Office, Ltd.

Today, we’re continuing our series of blogs from the Czech Republic. I would like to talk to you about persons who are US Taxpayers and who have Undisclosed Bank Accounts and other Foreign Assets in the Czech Republic.

What is it that they need to do once they find out about their prior tax noncompliance? First of all, we need to figure out who is a US Tax Resident. “US Tax Resident“, is a broad category; it includes all US Citizens, all US Permanent Residents and everyone who satisfied the Substantial Presence Test.

Now this definition, in its pure form, applies only to the income tax return. When we talk about forms like FBAR, Form 8938 and other similar US International Information Returns, the definition changes. It doesn’t change much but it does change a little bit. For FBAR purposes we’re talking about US Persons; if we are talking about Form 8938, we’re talking about Specified Individuals and Specified Domestic Entities.

The difference between these definitions, as I said, is very small, but there are differences. In some instances, you can be a non-resident alien for income tax purposes and still have to file FBAR. Similarly, you may have to file FBAR but you don’t have to file Form 8938. It is the job of your International Tax Attorney to determine which form applies to you, whether you are a US Tax Resident for a certain form and a non-resident with respect to an income tax return.

The most important thing is if you fall into any of the categories that I’ve mentioned, you are a US Tax Resident for income tax purposes. So, whether you are US Citizen, a US Permanent Resident or you satisfied the Substantial Presence Test, if you satisfy any of these requirements, then you have to disclose your Foreign Accounts and if you have not disclosed your accounts, then at that point you need to contact an International Tax Attorney; that’s the first step that you need to do.

Contact me in order to determine what your penalty exposure is and what the best way is to conduct your Voluntary Disclosure.

You can call me at (952) 500-8159 or you can email me at [email protected].

Thank you for watching!

International Tax Law Firm | Sherayzen Law Office, Ltd.

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This seminar is organized by the International Business Law Section and co-sponsored by the Trust Law Section of the Minnesota State Bar Association. My name is Eugene Sherayzen and I’ll be your speaker today.

First, a few words about myself; then we’ll get to the subject matter of today’s presentation.

I’m an International Tax Attorney and owner of Sherayzen Law Office, Ltd., a law firm that specializes in International Tax Compliance, in particular, Offshore Voluntary Disclosures, International Tax Planning and Annual US International Tax Compliance.

Over the course of my practice, I’ve conducted literally hundreds of Offshore Voluntary Disclosures of every type, including the IRS Offshore Voluntary Disclosure Program, the last version which closed on September 28, 2018, Streamlined Domestic Offshore Procedures, Streamlined Foreign Offshore Procedures, Delinquent FBAR Submission Procedures, Delinquent Information Return Submissions and Reasonable Cause Disclosures.

Every year, I’ve filed hundreds of income and information tax returns as part of my Annual Compliance and International Tax Practice.

As of the end of 2018, I’ve dealt with assets in over 70 countries and I have conducted Tax Compliance with respect to pretty much every major asset class and every type of major Business Tax Transaction. So, we’re talking about disclosure of Foreign Bank and Financial Accounts, Foreign Business Ownership, Foreign Corporations, Foreign Partnerships, Foreign Trusts, Foreign Gifts and Foreign Inheritance.

Here is the list of most countries where the clients of Sherayzen Law Office, Ltd. have assets: Australia, Canada, Cook Islands, New Zealand, Western Europe (Austria, Belgium, France, Germany, Iceland, Ireland, Italy, Liechtenstein, Luxembourg, Monaco, Portugal, Spain, Sweden, Switzerland and United Kingdom), Eastern Europe (Belarus, Croatia, Cyprus, Czech Republic, Hungary, Lithuania, Poland, Russian Federation and Ukraine), Asia (Bangladesh, China, Hong Kong, India, Japan, Kazakhstan, Philippines, Singapore, South Korea, Thailand, Uzbekistan and Vietnam), Middle East (Dubai, Egypt, Iran, Iraq, Israel, Jordan, Kuwait, Lebanon, Oman and Turkey), Africa (Cote D’Ivore, Ethiopia, Morocco, Nigeria and Sudan), the Caribbean region (Bahamas, Barbados, Jamaica, Saint Kitts and Nevis, Trinidad & Tobago and Cayman Islands), and Latin America (Argentina, Belize, Brazil, Chile, Colombia, Costa Rica, El Salvador, Nicaragua, Mexico, Panama and Paraguay).

Here is the list of states of the United States in which you can retain Sherayzen Law Office’s international tax services: Alabama, Alaska, Arizona, Arkansas, California, Colorado, Connecticut, Delaware, Florida, Georgia, Hawaii, Idaho, Illinois, Indiana, Iowa, Kansas, Kentucky, Louisiana, Maine, Maryland, Massachusetts, Michigan, Minnesota, Mississippi, Missouri, Montana, Nebraska, Nevada, New Hampshire, New Jersey, New Mexico, New York, North Carolina, North Dakota, Ohio, Oklahoma, Oregon, Pennsylvania, Rhode Island, South Carolina, South Dakota, Tennessee, Texas, Utah, Vermont, Virginia, Washington, West Virginia, Wisconsin, Wyoming.

Julius Baer & Importance of FATCA Compliance | Zurich FATCA Tax Lawyer

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Hello, and welcome to Sherayzen Law Office video blog. My name is Eugene Sherayzen; I’m an International Tax Attorney and owner of Sherayzen Law Office, Ltd.

Today, we are continuing our vlog from Zurich, Switzerland. We are standing in front of the Julius Baer or Baer Bank here in downtown Zurich. Julius Baer is a Multinational Private Bank which was investigated by the IRS and entered into the anti-prosecution deferral agreement with the US Department of Justice in 2016; it paid over $500 million dollars in Penalties and agreed to disclose all of its US Clients to the Department of Justice.

A bank which does not comply with US Tax Reporting Requirements, which assists US Taxpayers in hiding foreign income or foreign assets is likely to draw the wrath of the US Department of Justice and may face criminal prosecution from the US Government.

This is why it is important for Foreign Financial Institutions to stay in Compliance with FATCA and CRS. If you are a banker who is interested in developing a FATCA Compliance Program for your bank, contact me directly at (952) 500-8159 or email me at [email protected].

Thank you for watching, until the next time.