Minneapolis Foreign Trust Attorney | International Tax Lawyer

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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 a leading US international tax firm concerning US tax compliance of US beneficiaries and owners of a foreign trust. Our experience covers US taxpayers with a beneficiary and/or ownership interest in most of the countries that allow for the creation of a trust, including such important jurisdictions as: Australia, the Bahamas, Bermuda, Canada, Cook Islands, India, Japan, Jersey, New Zealand, Saint Kitts and Nevis, the United Kingdom and others. We also have an experience dealing with trusts organized in the United States that are treated as foreign trusts and, vice versa, trusts organized outside of the United States but treated as US trusts.

Minneapolis Foreign Trust Attorney: Foreign Trust Annual US Tax Compliance

Sherayzen Law Office is an experienced US international tax law firm that helps its clients to stay in full compliance with the US international tax reporting requirements concerning foreign trusts, including Forms 3520, 3520-A, 4970, 8938 and FBAR. This applies to both, US beneficiaries and US owners (including US grantors, US trustees and deemed US owners) of a foreign trust.

Minneapolis Foreign Trust Attorney: Foreign Trust Offshore Voluntary Disclosure

Sherayzen Law Office also helps its clients to remedy past noncompliance with respect to reporting of their beneficiary and/or ownership interests in a foreign trust as well as income from a foreign trust.  The primary legal vehicle for remedying such past tax noncompliance is an offshore voluntary disclosure.

Since 2005, Sherayzen Law Office has developed a profound expertise in all forms of offshore voluntary disclosures, including: Streamlined Domestic Offshore Procedures, Streamlined Foreign Offshore Procedures, Delinquent International Information Return Submission Procedures and Reasonable Cause voluntary disclosure (also known as “Noisy Disclosures” or “Statutory Disclosures”).   Due to its unique expertise, our firm is able to handle both, the legal and the accounting sides of an offshore voluntary disclosure; i.e. we prepare all of the legal documents and tax forms for you within one firm.

Minneapolis Foreign Trust Attorney: Foreign Trust Tax Planning

Sherayzen Law Office assists its clients with all aspects of US tax planning concerning foreign trusts.  Foreign trust tax planning can be very complex and involve multiple tax jurisdictions, but it remains one of the most effective tools to ethically and legally reduce your current income tax compliance burden.

Minneapolis Foreign Trust Attorney:  Challenging IRS Classification and IRS Penalties

Sherayzen Law Office represents its clients before the IRS with respect to challenging IRS classification of a foreign trust as well as high IRS penalties imposed for prior tax noncompliance concerning foreign trusts.

Contact Sherayzen Law Office for Professional Help With Your US International Tax Compliance Concerning Your Beneficiary or Ownership Interest in a Foreign Trust

Timing is highly important in cases involving a foreign trust. Hence, if you have a beneficiary or ownership interest in a foreign trust, you contact us in order to maximize the positive impact of our involvement.

We can help You! Contact Us Today to Schedule Your Confidential Consultation!

Denver FBAR Attorney | International Tax Lawyer Colorado

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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 is very important to understand that, by looking for Denver FBAR attorney, in reality, you are searching for an international tax lawyer who specializes in FBAR compliance.

The reason for this conclusion is the fact that FBAR enforcement belongs to a very special field of US tax law – US international tax law. FBAR is an information return concerning foreign assets, which necessarily involves US international tax compliance concerning foreign assets/foreign income. Moreover, ever since the FBAR enforcement was turned over to the IRS in 2001, the term FBAR attorney applies almost exclusively to tax attorneys.

Hence, when you look for an FBAR attorney, you are looking for an international tax attorney with a specialty in FBAR compliance.

Denver FBAR Attorney: Broad Scope of Compliance and Offshore Voluntary Disclosures

When retaining Denver FBAR attorney, consider the fact that such an attorney’s work is not limited only to the preparation and filing of FBARs. Rather, the attorney should be able to deliver a variety of tax services and freely operate with experience and knowledge in all relevant areas of US international tax law, including the various offshore voluntary disclosure options concerning delinquent FBARs.

Moreover, as part of an offshore voluntary disclosure, an FBAR Attorney often needs to amend US tax returns, properly prepare foreign financial statements according to US GAAP, correctly calculate PFICs, and complete an innumerable number of other tasks.

Mr. Sherayzen and his team of motivated experienced tax professionals of Sherayzen Law Office have helped hundreds of US taxpayers worldwide to bring their tax affairs into full compliance with US tax laws. This work included the preparation and filing of offshore voluntary disclosures concerning delinquent FBARs. Sherayzen Law Office offers help with all kinds of offshore voluntary disclosure options, including: SDOP (Streamlined Domestic Offshore Procedures), SFOP (Streamlined Foreign Offshore Procedures), DFSP (Delinquent FBAR Submission Procedures), DIIRSP (Delinquent International Information Return Submission Procedures), IRS VDP (IRS Voluntary Disclosure Practice) and Reasonable Cause disclosures.

Denver FBAR Attorney: Out-Of-State International Tax Lawyer

Whenever you are looking for an attorney who specializes in US international tax law (which is a federal area of law, not a state one), you do not need to limit yourself to lawyers who reside in Denver, Colorado. On the contrary, consider international tax attorneys who reside in other states and help Denver residents with their FBAR compliance.

Contact Sherayzen Law Office for Professional FBAR Help

Sherayzen Law Office is an international tax law firm that specializes in US international tax compliance, including FBARs. While our office is in Minneapolis, Minnesota, we help taxpayers who reside throughout the United States, including Denver, Colorado.

Thus, if you are looking for a Denver FBAR Attorney, contact Mr. Sherayzen as soon as possible to schedule Your Confidential Consultation!

Streamlined Domestic Offshore Procedures Lawyer: 2024 SDOP Advantages

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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 SDOP Advantages: Background Information and General Requirements

The IRS created the Streamlined Domestic Disclosure as an offshore voluntary disclosure option on June 18, 2014. The IRS specifically the designed Streamlined Domestic Disclosure to address the critique of many practitioners and taxpayers that the 2012 OVDP did not adequately deal with US taxpayers who non-willfully violated their US tax obligations (for example, in cases where the taxpayers simply did not know about the existence of FBAR or Form 8938).

Any taxpayer can participate in the SDOP as long as he satisfies all six parts of this option’s eligibility criteria: US tax residency, not eligible for Streamlined Foreign Offshore Procedures (“SFOP”), original US tax returns filed for the past three years, foreign income and information return (such as FBAR or Form 8938) violations, absence of IRS examination or investigation and non-willfulness.

If a taxpayer satisfies the eligibility criteria, he then must comply with all of the required submissions. The key requirement here is the certification under the penalty of perjury that the taxpayer’s prior tax noncompliance was non-willful. This requirement is the heart of the Streamlined Domestic Disclosure and must be approached with special care.

The other requirements include filing of amended tax returns for the past three years (with all of the necessary information returns), filing FBARs for the past six years, payment of tax due with interest and payment of Miscellaneous Offshore Penalty. Other requirements may also apply depending on the specific situation of a taxpayer.

2024 SDOP Offers a Number of Advantages to Noncompliant US Taxpayers

While the list of the requirements above may seem like a lot of work, in reality, Streamlined Domestic Offshore Procedures definitely offers a number of advantages compared to other offshore voluntary disclosure options. I will discuss in this article only the main four advantages.

Keep in mind that the SDOP may not always be advantages to taxpayers. There are plenty of situations where other offshore voluntary disclosure options may be superior to the SDOP.

I also wish to emphasize that the analysis of advantages or disadvantages of a particular voluntary disclosure option is highly fact-specific. I strongly recommend that you contact Sherayzen Law Office for a detailed analysis of your voluntary disclosure options before you even attempt to proceed with your offshore voluntary disclosure.

2024 SDOP Advantages: Easier Risk Management

One of the greatest advantages (though, the one rarely discussed on the Internet) of the Streamlined Domestic Offshore Procedures is the opportunity this option offers to manage the voluntary disclosure risks. We can be even more precise – to manage the risk-reward ratio.

The 2024 SDOP is a disclosure option that offers a definitive transparent calculation of risks and rewards.  While the risks associated with non-willfulness are not always easy to determine, the rest of the SDOP framework, such as penalty rate, calculation of Penalty Base and other factors are generally (though, not always) much clearer than in riskier disclosure options such Noisy Disclosure, Delinquent International Information Return Submission Procedures (“DIIRSP”) and Reasonable Cause disclosures.

2024 SDOP Advantages: Legal Standard

Closely related to the risk management factor discussed above is another SDOP advantage of a lower legal standard of proof — non-willfulness. While proving non-willfulness can be a complicated and difficult process, it is still much easier than satisfying the reasonable cause standard.

The reasonable cause standard is immensely more difficult and tougher to meet for a taxpayer. Yet it is the statutory standard for penalty removal for pretty much every US international tax form outside of a voluntary disclosure. Reasonable cause is also the standard for even some other voluntary disclosure programs (for example, DIIRSP). Of course, IRS VDP does not require proving even non-willfulness, but its penalty system is a lot harsher than that of the SDOP.

2024 SDOP Advantages: Relatively Low Penalty Rate

One of the most cited advantages of the 2024 SDOP is the low penalty rate of 5%. This is usually a huge advantage over the very high IRS Voluntary Disclosure Practice (“VDP”) penalty rates or various penalties outside of a voluntary disclosure program (including in many cases FBAR non-willful penalties). This is not always the case, but it is true in most non-willful cases.

2024 SDOP Advantages: Shortened Voluntary Disclosure Period

Finally, another great advantage of Streamlined Domestic Offshore Procedures is the smaller number of years covered by the voluntary disclosure period. Unlike the old OVDP voluntary disclosure period (which used to cover eight years of FBARs and tax returns) and the current VDP voluntary disclosure period of up to six years, SDOP’s voluntary disclosure period only encompasses the years which are covered by a regular statute of limitations.

In other words, it only includes the past six years of FBARs (occasionally seven) and past three years of tax returns. Obviously, this is a lot more convenient than VDP.  It should be noted that a voluntary disclosure that involves an expatriation will require an increased number of amended tax returns.

Contact Sherayzen Law Office for Professional Help with Streamlined Domestic Disclosure

Even with all of its advantages, Streamlined Domestic Offshore Procedures may still be a very complex process that requires professional attention. There are a number of pitfalls that may seriously undermine the advantages of a Streamlined Domestic Disclosure. Sometimes, unrepresented taxpayers may also make mistakes that may have a disastrous result during a subsequent IRS audit.

This is why you need the professional help of Sherayzen Law Office. Our experienced legal team has helped hundreds of US taxpayers resolve their prior noncompliance with US international tax laws, including by using Streamlined Domestic Offsshore Procedures.

We Can Help You! Contact Us Today to Schedule Your Confidential Consultation!

Indiana Streamlined Disclosure Lawyer | International Tax Attorney

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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 receive income generated by these assets. Unfortunately some of these taxpayers are not in compliance with their US international tax obligations and want to participate in Streamlined Domestic Offshore Procedures (SDOP) or Streamlined Foreign Offshore Procedures (SFOP). These individuals often look for a Indiana streamlined disclosure lawyer for professional help, but they do not understand what this term really means. In this essay, I would like to explain the definition of Indiana streamlined disclosure lawyer and outline who belongs to this category of lawyers.

Indiana Streamlined Disclosure Lawyer: International Tax Attorney

From the outset, It is important to understand that all voluntary disclosures, including the Streamlined options, form part of US international tax compliance, because these options deal with US international tax laws concerning foreign assets and foreign income. The knowledge that SDOP and SFOP are part of US international tax law makes you better understand what kind of lawyer you are looking for when you search for a Indiana streamlined disclosure lawyer. In reality, when you are seeking help with the SDOP and SFOP filings, you are searching for an international tax attorney.

Indiana Streamlined Disclosure Lawyer: Specialty in Offshore Voluntary Disclosures

As I stated above, SDOP and SFOP form part of a very specific sub-area of offshore voluntary disclosures. This means that not every international tax attorney would be able to conduct the necessary legal analysis required to successfully complete an offshore voluntary disclosure, including Streamlined Domestic Offshore Procedures and Streamlined Foreign Offshore Procedures. Only a lawyer who has developed expertise in a very narrow sub-field of offshore voluntary disclosures within US international tax law will be fit for this job.

This means that you are looking for an international tax attorney who specializes in offshore voluntary disclosures and who is familiar with the various offshore voluntary disclosure options. Offshore voluntary disclosure options include: SDOP (Streamlined Domestic Offshore Procedures), SFOP (Streamlined Foreign Offshore Procedures), DFSP (Delinquent FBAR Submission Procedures), DIIRSP (Delinquent International Information Return Submission Procedures), IRS VDP (IRS Voluntary Disclosure Practice) and Reasonable Cause disclosures. Each of these options has it pros and cons, which may have tremendous legal and tax (and, in certain cases, even immigration) implications for your case.

Indiana Streamlined Disclosure Lawyer: Geographical Location Does Not Matter

While the expertise and experience in offshore voluntary disclosures is highly important in choosing your international tax lawyer, the geographical location (i.e. the city where the lawyer lives and works) does not matter. I already hinted at why this is the case above: offshore voluntary disclosure options were all created by the IRS and form part of US international (i.e. federal) law. In other words, the local law has no connection whatsoever to the SDOP and SFOP.

This means that you are not limited to Indiana when you are looking for a lawyer who can help you with your streamlined disclosure. Any international tax lawyer who specializes in this field may be able to help you, irrespective of whether this lawyer resides in Indiana or Minnesota.

Moreover, the development of modern means of communications has pretty much eliminated any communication advantages that a lawyer in Indiana might have had in the past over the out-of-state lawyers. This has already been established in today’s post-pandemic world which greatly reduced the number of face-to-face meetings.

Sherayzen Law Office May Be Your Indiana Streamlined Disclosure Lawyer

Sherayzen Law Office, Ltd. is a highly-experienced international tax Minnesota law firm that specializes in all types of offshore voluntary disclosures, including SDOP, SFOP, DFSP, DIIRSP, IRS VDP and Reasonable Cause disclosures. Our professional tax team, led by attorney Eugene Sherayzen, has successfully helped our US clients around the globe, including in Indiana, with the preparation and filing of their Streamlined Domestic Offshore Procedures disclosure. We can help you!

Contact Us Today to Schedule Your Confidential Consultation!

Cambridge FBAR Attorney | International Tax Lawyer Massachusetts

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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 is very important to understand that, by looking for Cambridge FBAR attorney, in reality, you are searching for an international tax lawyer who specializes in FBAR compliance.

The reason for this conclusion is the fact that FBAR enforcement belongs to a very special field of US tax law – US international tax law. FBAR is an information return concerning foreign assets, which necessarily involves US international tax compliance concerning foreign assets/foreign income. Moreover, ever since the FBAR enforcement was turned over to the IRS in 2001, the term FBAR attorney applies almost exclusively to tax attorneys.

Hence, when you look for an FBAR attorney, you are looking for an international tax attorney with a specialty in FBAR compliance.

Cambridge FBAR Attorney: Broad Scope of Compliance and Offshore Voluntary Disclosures

When retaining Cambridge FBAR attorney, consider the fact that such an attorney’s work is not limited only to the preparation and filing of FBARs. Rather, the attorney should be able to deliver a variety of tax services and freely operate with experience and knowledge in all relevant areas of US international tax law, including the various offshore voluntary disclosure options concerning delinquent FBARs.

Moreover, as part of an offshore voluntary disclosure, an FBAR Attorney often needs to amend US tax returns, properly prepare foreign financial statements according to US GAAP, correctly calculate PFICs, and complete an innumerable number of other tasks.

Mr. Sherayzen and his team of motivated experienced tax professionals of Sherayzen Law Office have helped hundreds of US taxpayers worldwide to bring their tax affairs into full compliance with US tax laws. This work included the preparation and filing of offshore voluntary disclosures concerning delinquent FBARs. Sherayzen Law Office offers help with all kinds of offshore voluntary disclosure options, including: SDOP (Streamlined Domestic Offshore Procedures), SFOP (Streamlined Foreign Offshore Procedures), DFSP (Delinquent FBAR Submission Procedures), DIIRSP (Delinquent International Information Return Submission Procedures), IRS VDP (IRS Voluntary Disclosure Practice) and Reasonable Cause disclosures.

Cambridge FBAR Attorney: Out-Of-State International Tax Lawyer

Whenever you are looking for an attorney who specializes in US international tax law (which is a federal area of law, not a state one), you do not need to limit yourself to lawyers who reside in Cambridge, Massachusetts. On the contrary, consider international tax attorneys who reside in other states and help Cambridge residents with their FBAR compliance.

Contact Sherayzen Law Office for Professional FBAR Help

Sherayzen Law Office is an international tax law firm that specializes in US international tax compliance, including FBARs. While our office is in Minneapolis, Minnesota, we help taxpayers who reside throughout the United States, including Cambridge, Massachusetts.

Thus, if you are looking for a Cambridge FBAR Attorney, contact Mr. Sherayzen as soon as possible to schedule Your Confidential Consultation!