Louisville FBAR Attorney | International Tax Lawyer Kentucky

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If you reside in Louisville, Kentucky and have unreported foreign bank and financial accounts, you may be looking for a Louisville FBAR Attorney.  Sherayzen Law Office, Ltd. is a leader in FBAR compliance, including offshore voluntary disclosures concerning delinquent FBARs, and you should consider us in your search. Let’s understand why this is the case.

Louisville FBAR Attorney: International Tax Lawyer

First of all, it is very important to understand that, by looking for Louisville 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.

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

When retaining Louisville 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.

Louisville 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 Louisville, Kentucky. On the contrary, consider international tax attorneys who reside in other states and help Louisville 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 Louisville, Kentucky.

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

Digital Currency Final Regulations: Broad Overview | Cryptocurrency Tax Attorney

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On June 28, 2024, the U.S. Department of the Treasury and the Internal Revenue Service (IRS) have issued final regulations requiring brokers to report sales and exchanges of digital assets, including cryptocurrency. These digital currency final regulations aim to improve tax compliance and provide taxpayers with necessary information for accurate tax reporting.

Digital Currency Final Regulations: Scope and Implementation

The new regulations will apply to transactions beginning in calendar year 2025, with reports to be filed on the new Form 1099-DA. These rules primarily affect custodial brokers who take possession of digital assets being sold by their customers, including:

  • Operators of custodial digital asset trading platforms
  • Certain digital asset hosted wallet providers
  • Digital asset kiosks
  • Certain processors of digital asset payments (PDAPs)

Notably, the regulations do not currently include reporting requirements for non-custodial or decentralized brokers. The Treasury and IRS plan to address these entities in a separate set of regulations in the future.

Digital Currency Final Regulations: Key Provisions

There are six key areas addressed in the final regulations:

  1. Basis, Gain, and Loss Determination: The regulations provide rules for taxpayers to determine their basis, gain, and loss from digital asset transactions. This is very important, because we will now have a more or less clear set of rules to follow.
  2. Backup Withholding: New rules for backup withholding on certain digital asset transactions are included. This is a critical issue, especially in the context of US international tax law.
  3. Real Estate Transactions: Real estate professionals must report the fair market value of digital assets used in real estate transactions with closing dates on or after January 1, 2026. Another key provision aimed to improve tax compliance in this area.
  4. Aggregate Reporting: An optional aggregate reporting method is provided for certain sales of stablecoins and non-fungible tokens (NFTs) that exceed specified thresholds.
  5. PDAP Transactions: Reporting is required on a transactional basis only if customer sales exceed a de minimis threshold.
  6. Basis Reporting: Certain brokers must report basis for transactions occurring on or after January 1, 2026. This is a very good provision for US taxpayers, because cost-basis determination is often very cumbersome when it comes to digital asset gain reporting.

Digital Currency Final Regulations: Transitional Relief and Exceptions

Obviously, the new reporting requirements is an increased compliance burden on affected custodial brokers. In order to ease this burden, the IRS is providing the following transitional and penalty relief:

  1. Notice 2024-56 offers general transitional relief from reporting penalties and backup withholding for brokers making good faith efforts to comply during calendar year 2025.
    Limited relief from backup withholding is provided for certain digital asset sales in 2026 for brokers using the IRS TIN-matching system.
  2. Notice 2024-57 temporarily exempts six types of transactions from reporting requirements, including wrapping and unwrapping transactions, liquidity provider transactions and staking transactions, among others.
  3. Revenue Procedure 2024-28 allows taxpayers to use reasonable allocation methods for unused basis across wallets or accounts holding the same digital asset.

Digital Currency Final Regulations: IRS Rationale

IRS Commissioner Danny Werfel emphasized the importance of these regulations in addressing potential noncompliance in digital currency transactions. The new reporting requirements are expected to improve detection of noncompliance and provide taxpayers with information to simplify their reporting process.

Werfel also highlighted the need for adequate IRS funding to keep pace with the evolving complexity of the tax system, particularly in relation to new digital assets.

Digital Currency Final Regulations: Impact

These Digital Currency Final Regulations represent a major development in the taxation and reporting of digital asset transactions, in particular with respect to integration of digital assets into the existing tax framework. As the digital asset landscape continues to evolve, further refinements and additional regulations are likely to follow, particularly regarding non-custodial and decentralized brokers. While the regulations provide clarity for many custodial brokers and taxpayers, the full impact of these regulations will become clearer as implementation begins in 2025 and beyond.

Contact Sherayzen Law Office for Professional Tax Help With US International Tax Aspects of Digital Currencies

Given the complex and evolving nature of digital currency regulations, it is crucial to seek expert guidance. Sherayzen Law Office specializes in US international tax law and can provide invaluable assistance in navigating the intricate landscape of digital currency taxation across borders. Contact us today to schedule your confidential consultation!

Indianapolis FBAR Attorney | International Tax Lawyer Indiana

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If you reside in Indianapolis, Indiana and have unreported foreign bank and financial accounts, you may be looking for a Indianapolis FBAR Attorney.  Sherayzen Law Office, Ltd. is a leader in FBAR compliance, including offshore voluntary disclosures concerning delinquent FBARs, and you should consider us in your search. Let’s understand why this is the case.

Indianapolis FBAR Attorney: International Tax Lawyer

First of all, it is very important to understand that, by looking for Indianapolis 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.

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

When retaining Indianapolis 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.

Indianapolis 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 Indianapolis, Indiana. On the contrary, consider international tax attorneys who reside in other states and help Indianapolis 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 Indianapolis, Indiana.

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

Waco Foreign Inheritance Lawyer | International Tax Attorney Texas

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Retaining a Waco foreign inheritance lawyer to deal with the IRS is very likely to be necessary if you reside in Waco, Texas and have received an inheritance from a non-resident alien (i.e. foreign inheritance).  Sherayzen Law Office, Ltd. is a leader in US international tax compliance concerning foreign inheritance, including offshore voluntary disclosures concerning late disclosure of a foreign inheritance, and may be your Waco foreign inheritance lawyer.

Waco Foreign Inheritance Lawyer: Why Foreign Inheritance is Important to Your US international Tax Compliance

Receiving a foreign inheritance requires proper US international tax compliance in five areas: disclosure of foreign inheritance to the IRS, information reporting requirements that are linked to foreign inheritance, classification and recognition of income linked to foreign inheritance (including special requirements concerning inheritance of foreign real estate), inheritance of US-situs property and transfers of cash/assets to the United States.

Each of these areas of foreign inheritance has its own complications, traps and important reporting reporting requirements. These reporting requirements may have important tax implications with potentially high noncompliance IRS penalties.

This is precisely why it is highly recommended to consult a tax lawyer if you received or about to receive foreign inheritance. However, not every tax attorney would be the right fit for your foreign inheritance case.  In order to be properly classified as a Waco foreign inheritance lawyer, the lawyer must be an international tax attorney with extensive experience in various US international tax reporting requirements related to foreign inheritance.

Waco Foreign Inheritance Lawyer: International Tax Attorney

A foreign inheritance lawyer is first and foremost an international tax attorney – i.e. a lawyer with profound knowledge of and extensive experience in US international tax law, particularly in the area of US international tax compliance. This means that a lawyer must be familiar with such common US international tax forms as: Form 3520 (critically important for foreign inheritance reporting) and Form 8938.  He must also understand related US international tax compliance forms such as Forms 3520-A, 5471, 8865, 8858, et cetera.  Of course, every US international tax lawyer must be very familiar with FinCEN Form 114 commonly known as FBAR.

In addition to information returns, an international tax lawyer must be familiar with all types of foreign income reporting.  This requirement includes the knowledge of such distinct areas of international income tax reporting sub-areas as foreign rental income, PFIC compliance, GILTI income, capital gains concerning foreign real estate, et cetera.

Sherayzen Law Office is a highly-experienced and highly-knowledgeable international tax law firm with respect to all of the aforementioned income tax and information return requirements, including all of the aforementioned forms.

Waco Foreign Inheritance Lawyer: Tax Planning

In cases where it is possible, it is highly prudent to engage in tax planning concerning a foreign inheritance. This is important not only for the purpose of limiting future tax burdens, but also to control future US tax compliance costs.  Hence, when you look for a Waco foreign inheritance attorney, you should retain a law firm which has experience with foreign inheritance US tax planning.

Sherayzen Law Office has an extensive experience in foreign inheritance US tax planning for its clients in Waco and all over the world.  We also have a highly valuable experience of combining income tax planning with offshore voluntary disclosures.

Waco Foreign Inheritance Lawyer: Offshore Voluntary Disclosures

When retaining a Waco Foreign Inheritance Lawyer, consider the fact that such an attorney’s work may not limited only to the current or future US international tax compliance. In my experience, a discussion of a foreign inheritance often involves identification and remedying of past US international tax noncompliance. In other words, foreign inheritance issues often lead to engaging in an IRS offshore voluntary disclosure option.

This means that a Waco Foreign Inheritance Lawyer should be very familiar with all offshore voluntary disclosure options.

Offshore Voluntary Disclosures is a core area of the our international tax practice at Sherayzen Law Office. We have helped hundreds of US taxpayers worldwide, including in Waco, to bring their tax affairs into full compliance with US tax laws. This work included the preparation and filing of all kinds of offshore voluntary disclosures including: SDOP (Streamlined Domestic Offshore Procedures), SFOP (Streamlined Foreign Offshore Procedures), DFSP (Delinquent FBAR Submission Procedures), DIIRSP (Delinquent International Information Return Submission Procedures), et cetera.

Waco Foreign Inheritance Lawyer: 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 Waco, Texas. On the contrary, consider international tax attorneys who reside in other states and help Waco residents with their FBAR compliance.

Sherayzen Law Office is based in Minneapolis, Minnesota, but we have a large number of clients in Texas, including the Waco area. Hence, Waco residents can contact us and retain us to resolve their foreign inheritance issues related to US international tax compliance.

Contact Sherayzen Law Office for Professional Foreign Inheritance Tax Help

Sherayzen Law Office is an international tax law firm that specializes in US international tax compliance, including foreign inheritance reporting.  We have helped numerous clients in Texas with their foreign inheritance. We can help you!

Hence, if you are looking for a Waco Foreign Inheritance Lawyer, contact Mr. Sherayzen now to schedule Your Confidential Consultation!

Abilene Foreign Inheritance Lawyer | International Tax Attorney Texas

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Retaining a Abilene foreign inheritance lawyer to deal with the IRS is very likely to be necessary if you reside in Abilene, Texas and have received an inheritance from a non-resident alien (i.e. foreign inheritance).  Sherayzen Law Office, Ltd. is a leader in US international tax compliance concerning foreign inheritance, including offshore voluntary disclosures concerning late disclosure of a foreign inheritance, and may be your Abilene foreign inheritance lawyer.

Abilene Foreign Inheritance Lawyer: Why Foreign Inheritance is Important to Your US international Tax Compliance

Receiving a foreign inheritance requires proper US international tax compliance in five areas: disclosure of foreign inheritance to the IRS, information reporting requirements that are linked to foreign inheritance, classification and recognition of income linked to foreign inheritance (including special requirements concerning inheritance of foreign real estate), inheritance of US-situs property and transfers of cash/assets to the United States.

Each of these areas of foreign inheritance has its own complications, traps and important reporting reporting requirements. These reporting requirements may have important tax implications with potentially high noncompliance IRS penalties.

This is precisely why it is highly recommended to consult a tax lawyer if you received or about to receive foreign inheritance. However, not every tax attorney would be the right fit for your foreign inheritance case.  In order to be properly classified as a Abilene foreign inheritance lawyer, the lawyer must be an international tax attorney with extensive experience in various US international tax reporting requirements related to foreign inheritance.

Abilene Foreign Inheritance Lawyer: International Tax Attorney

A foreign inheritance lawyer is first and foremost an international tax attorney – i.e. a lawyer with profound knowledge of and extensive experience in US international tax law, particularly in the area of US international tax compliance. This means that a lawyer must be familiar with such common US international tax forms as: Form 3520 (critically important for foreign inheritance reporting) and Form 8938.  He must also understand related US international tax compliance forms such as Forms 3520-A, 5471, 8621, 8865, 8858, et cetera.  Of course, every US international tax lawyer must be very familiar with FinCEN Form 114 commonly known as FBAR.

In addition to information returns, an international tax lawyer must be familiar with all types of foreign income reporting.  This requirement includes the knowledge of such distinct areas of international income tax reporting sub-areas as foreign rental income, PFIC compliance, GILTI income, capital gains concerning foreign real estate, et cetera.

Sherayzen Law Office is a highly-experienced and highly-knowledgeable international tax law firm with respect to all of the aforementioned income tax and information return requirements, including all of the aforementioned forms.

Abilene Foreign Inheritance Lawyer: Tax Planning

In cases where it is possible, it is highly prudent to engage in tax planning concerning a foreign inheritance. This is important not only for the purpose of limiting future tax burdens, but also to control future US tax compliance costs.  Hence, when you look for a Abilene foreign inheritance attorney, you should retain a law firm which has experience with foreign inheritance US tax planning.

Sherayzen Law Office has an extensive experience in foreign inheritance US tax planning for its clients in Abilene and all over the world.  We also have a highly valuable experience of combining income tax planning with offshore voluntary disclosures.

Abilene Foreign Inheritance Lawyer: Offshore Voluntary Disclosures

When retaining a Abilene Foreign Inheritance Lawyer, consider the fact that such an attorney’s work may not limited only to the current or future US international tax compliance. In my experience, a discussion of a foreign inheritance often involves identification and remedying of past US international tax noncompliance. In other words, foreign inheritance issues often lead to engaging in an IRS offshore voluntary disclosure option.

This means that a Abilene Foreign Inheritance Lawyer should be very familiar with all offshore voluntary disclosure options.

Offshore Voluntary Disclosures is a core area of the our international tax practice at Sherayzen Law Office. We have helped hundreds of US taxpayers worldwide, including in Abilene, to bring their tax affairs into full compliance with US tax laws. This work included the preparation and filing of all kinds of offshore voluntary disclosures including: SDOP (Streamlined Domestic Offshore Procedures), SFOP (Streamlined Foreign Offshore Procedures), DFSP (Delinquent FBAR Submission Procedures), DIIRSP (Delinquent International Information Return Submission Procedures), et cetera.

Abilene Foreign Inheritance Lawyer: 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 Abilene, Texas. On the contrary, consider international tax attorneys who reside in other states and help Abilene residents with their FBAR compliance.

Sherayzen Law Office is based in Minneapolis, Minnesota, but we have a large number of clients in Texas, including the Abilene area. Hence, Abilene residents can contact us and retain us to resolve their foreign inheritance issues related to US international tax compliance.

Contact Sherayzen Law Office for Professional Foreign Inheritance Tax Help

Sherayzen Law Office is an international tax law firm that specializes in US international tax compliance, including foreign inheritance reporting.  We have helped numerous clients in Texas with their foreign inheritance. We can help you!

Hence, if you are looking for a Abilene Foreign Inheritance Lawyer, contact Mr. Sherayzen now to schedule Your Confidential Consultation!