2019 Zurich Trip Completed | Zurich US International Tax Lawyer & Attorney

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In July of 2019, Mr. Eugene Sherayzen, an international tax attorney and owner of Sherayzen Law Office, Ltd., completed his business trip to Zurich, Switzerland. Let’s discuss in more detail this 2019 Zurich Trip, its goals and accomplishments.

2019 Zurich Trip: Goals

Mr. Sherayzen outlined the firm’s goals for the Zurich trip during the Sherayzen Law Office Board of Director’s meeting on March 19, 2019. At the beginning of the meeting, he outlined two long-term goals for Sherayzen Law Office: (1) deepen the firm’s ties to the global banking and investment community, and (2) promote Sherayzen Law Office’s international tax services in Europe.

Mr. Sherayzen stated that the particular goals for the 2019 Zurich trip were as follows: (1) gather the necessary intelligence to achieve the long-term goals; (2) resolve certain issues for the firm’s current clients with Swiss bank accounts; and (3) make promotional videos of the firm’s services.

2019 Zurich Trip: Achievements

The 2019 Zurich trip achieved all of the goals that were outlined above. During the trip, Mr. Sherayzen gathered a large amount of data that will need to be analyzed in the future for the purpose of improving the firm’s marketing strategies.

Second, while in Zurich, Mr. Sherayzen successfully resolved all of the pending issues for the firm’s clients.

Finally, a number of videos were made for the purpose of promoting the vast experience and deep expertise that Sherayzen Law Office has accumulated in US international tax law. Sherayzen Law Office is a leader in US international tax compliance, including offshore voluntary disclosures.

2019 Zurich Trip and Future Plans

Sherayzen Law Office intends to capitalize in the near future on the achievements made by Mr. Sherayzen during this trip. We encourage our clients and followers on social media to stay tuned for future updates, including video updates.

The Board of Directors of Sherayzen Law Office, Ltd., will analyze the successes of the 2019 Zurich trip in order to modify the plans for the firm’s marketing strategies in Europe. The Board already commenced planning for new targeted trips which will lead to the expansion of the firm’s clientele in Europe.

Sherayzen Law Office already has a very large exposure in the European continent. We have helped clients with undisclosed European assets in most countries on the European continent: Austria, Belarus, Belgium, Croatia, Cyprus, the Czech Republic, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Liechtenstein, Lithuania, Luxembourg, Monaco, Poland, Portugal, Romania, the Russian Federation, Spain, Sweden, Switzerland, United Kingdom and Ukraine.

Contact Sherayzen Law Office for Professional Help With Your US International Tax Compliance

Sherayzen Law Office is a US international tax law firm with deep expertise in all relevant areas of US international tax law, including offshore voluntary disclosures. With clients from over 70 countries around the world, our firm is a leader in US international tax compliance.

We have helped hundreds of US taxpayers around the world with their US international tax compliance issues, and We can help You! Contact Us Today to Schedule Your Confidential Consultation!

2019 Karlovy Vary Trip Completed | US International Tax Lawyer & Attorney

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Mr. Eugene Sherayzen, an international tax attorney and owner of Sherayzen Law Office, Ltd., completed his trip to Karlovy Vary, Czech Republic, on July 10, 2019. Let’s discuss in more detail this brief 2019 Karlovy Vary trip, its motivations and results.

2019 Karlovy Vary Trip: Reasons for this Excursion

There were several reasons why Mr. Sherayzen decided to undertake this trip to Karlovy Vary. He outlined them at the Sherayzen Law Office board of directors meeting on March 19, 2019.

First, this is part of the firm’s overall expansion effort into the European market of high-net worth individuals.

Second, this is a very attractive venue for new clients from all over the world, because Karlovy Vary is a world-famous resort. It is important for Sherayzen Law Office to establish a foothold in this city.

Third, Karlovy Vary offers amazing scenery which is perfect for filming promotional videos for the firm.

Finally, the 2019 Karlovy Vary trip was undertaken during Mr. Sherayzen’s Switzerland-Prague business trip. In other words, it was very a convenient time for a journey into this prestigious European high-end legal market.

2019 Karlovy Vary Trip: Results

The 2019 Karlovy Vary trip was very successful in three aspects. First of all, the firm now has acquired certain information about the city sufficient to commence building a comprehensive marketing strategy. Second, the trip laid basis for several business relationships which the firm hopes to explore further in the future. Finally, a large set of promotional material was created during the trip.

Despite its successes, the 2019 Karlovy Vary trip was merely an exploratory marketing trip. In order to build a more solid foothold in the city, Mr. Sherayzen and the employees of Sherayzen Law Office will need to continue to visit the city on a more sustained basis.

2019 Karlovy Vary Trip: What Sherayzen Law Office Can Offer to Its European Clients

Sherayzen Law Office specializes in US international tax compliance, including offshore voluntary disclosures, current tax compliance and international tax planning. Europeans who reside in Europe, but who are US citizens or US permanent residents, may be exposed to high IRS non-compliance penalties. This is why they should contact Sherayzen Law Office for professional help with US international tax compliance requirements.

Contact Us Today to Schedule Your Confidential Consultation!

Legal Entity Identifiers: Introduction to LEI | International Tax Lawyer & Attorney

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The Legal Entity Identifiers (“LEI”) is a method to identify legal entities that engage in financial transactions. Let’s discuss LEI in more detail.

LEI: Background Information

The establishment of LEI was driven by the recognition by regulators around the world that there is a complete lack of transparency with respect to identifying parties to international transactions. Each business entity is registered at the national level, but another country’s authorities would have great difficulty identifying this entity in an international transaction, including whether this entity has taken consistent tax positions in both countries.

Establishment of LEI; Additional Initiatives

Hence, on the initiative of the largest twenty economies of the world (“G-20“), the Financial Stability Board (“FSB”) developed the framework of Global LEI System (“GLEIS”). FSB was created in 2009 in the aftermath of the financial crisis (it replaced the Financial Stability Forum or “FSF”).

Additionally, in January of 2013, a LEI Regulatory Oversight Committee (“ROC”) was created. ROC is a group of over 70 public authorities from member-countries and additional observers from more than 50 countries. The job of the ROC is coordination and oversight of the worldwide LEI framework.

On May 9, 2017, the ROC announced that it has launched data collection on parent entities in the Global Legal Entity Identifiers System – this is the so-called “relationship data”. The member countries (especially in the European Union (“EU”)) will use this data in a number of regulatory initiatives. For example, as of 2018, the EU uses the relationship data for the purposes of commodity derivative reporting.

How LEI Works

The LEI is a 20-character, alpha-numeric code, to uniquely identify legally distinct entities that engage in financial transactions. The code incorporates the following information:

1.the official name of the legal entity as recorded in the official registers;
2.the registered address of that legal entity;
3.the country of formation;
4.codes for the representation of names of countries and their subdivisions;
5.the date of the first Legal Entity Identifier assignment; the date of last update of the information; and the date of expiration, if applicable.

Here is how the numbering system works:

•Characters 1–4: A four-character prefix allocated uniquely to each LOU.
•Characters 5–6: Two reserved characters set to zero.
•Characters 7–18: Entity—specific part of the code generated and assigned by LOUs according to transparent, sound, and robust allocation policies.
•Characters 19–20: Two check digits as described in the ISO 17442 standard.

Jurisdictions With Rules Referring to LEI

Over 40 jurisdictions have rules that refer to Legal Entity Identifiers: Argentina, Australia, Canada, 31 members of the European Union and European Economic Area, Hong Kong, India, Israel, Mexico, Russia, Singapore, Switzerland, and the United States. IGOs such as Basel Committee on Banking Supervision and International Organization of Securities Commissions also use Legal Entity Identifiers.

Could LEI Be Used for CRS and FATCA Purposes?

Sherayzen Law Office, like many other commentators, believes that there is a possibility that the LEI would be a better alternative than Global Intermediary Identification Number (GIIN) for CRS and FATCA purposes. First of all, it would be more efficient to have one identification system across all compliance terrains. Second, Legal Entity Identifiers are actually more popular than GIINs. As of December 7, 2017, there were 830,477 LEIs issued versus a mere less than 300,000 GIINs.

IRS Appeals Video Conference | IRS Tax Lawyer & Attorney

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In May of 2019, Mr. Andrew Keyso, a deputy chief of the IRS Office of Appeals, stated that the Appeals Office is in the early stages of rolling out the technology to conduct video conferences as an option for Appeals conferences. This is great news for tax practitioners – an IRS Appeals video conference is a very convenient option for doing business with the IRS.

IRS Appeals Video Conference: WebEx Platform and Early Testing

The IRS Appeals video conference option will be based on WebEx video conferencing software developed by Cisco. It is secure and convenient, but some training is necessary to use it efficiently.

The IRS has already successfully tested WebEx software for appeals video conferences in early 2018. In October of 2018, IRS made the software more broadly available to its employees so that they can offer video conferences.

IRS Appeals Video Conference: IRS Wants Employees to Use It More

Unfortunately, not all IRS employees at the Appeals Office offer video conferences. Neither do many taxpayers seek them (undoubtedly due to lack of knowledge about them). Those who do so, however, find this option very attractive.

The IRS definitely wants its employees to use the IRS Appeals video conference option more. Speaking at the American Bar Association Section of Taxation conference in May of 2019, Diane Ogawa, an IRS appeals officer in Honolulu, stated: “We are trying to get more appeals officers training and on board with WebEx”. Sherayzen Law Office believes that, as more Appeals employees, taxpayers and tax practitioners become familiar with WebEx, the usage of the IRS Appeals video conference option should greatly increase.

IRS Appeals Video Conference: Positive Reaction from Tax Lawyers

The tax lawyers are generally in favor of using the IRS Appeals video conference option. They find it a convenient and effective way to conduct a hearing conference. There is also an additional benefit of reduced costs: there is no need to waste time and money on traveling to the IRS office.

IRS Appeals Video Conference: Potential Problems

This option, however, is not without potential problems. Besides the potential technical issues, the biggest problem is privacy. An unrepresented taxpayer may try to hold a video conference in a public place (like Starbucks) and the IRS will simply not agree to it. A represented taxpayer will not likely run into this problem, because his representative should know about these privacy issues.

The bigger privacy concern, though, comes from tax lawyers. They need to make sure that the prying eye of WebEx technology does not catch the other clients’ files, names and so on in the background of the WebEx video. Lawyers should strive to protect the attorney-client privileged information to the maximum extent possible.

Sherayzen Law Office Supports the IRS Video Conference Option and Hopes the IRS Expands It to Audit Interviews

As an international tax law firm, Sherayzen Law Office has clients throughout the United States and, indeed, the world. Flying to a meeting with an IRS agent is sometimes inconvenient for both, the taxpayer and the attorney; it is also expensive. Video conferencing is a perfect solution to this issue, and Sherayzen Law Office fully supports the current IRS video conferencing efforts.

Moreover, we encourage the IRS to apply video conferencing to other areas, such as IRS audit meetings.

Finnish US Bank Accounts Face IRS John Doe Summonses | FATCA News

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On May 1, 2019, the United States District Court for the Western District of North Carolina (the “Court”) authorized the IRS to serve John Doe Summonses seeking information about Finnish residents who own secret US bank accounts (collectively Finnish US Bank Accounts). Let’s discuss this development concerning Finnish US bank accounts in more depth.

Finnish US Bank Accounts Targeted by the Finnish Tax Administration.

This whole case is about the Finnish government’s efforts to identify noncompliant Finnish taxpayers who failed to disclose income related to their non-Finnish bank accounts. Specifically, the Finnish Tax Administration (“FTA”) identified bank accounts in the United States owned by Finnish tax residents as one of the primary targets in its tax enforcement campaign.

The reason why Finland cannot identify the affected individuals itself is because, in circumstances where the payment cards are used only at ATMs or in other transactions where authorization is by PIN code, and the cardholder need not identify himself or herself to the merchant, the cardholders cannot be identified from sources in Finland. Earlier FTA investigations of approximately 120 to 150 Finnish taxpayers who used foreign payment cards in a similar manner have yielded extremely high rates of tax non-compliance, as noted in the United States’ memo in support of the petition, which indicates that it is likely that the John Does sought by the summons are Finnish residents who are failing to report these foreign accounts and associated income.

Hence, the FTA asked the US Department of Justice (“DOJ”) and the IRS for help as prescribed by the tax treaty between Finland and the United States. The treaty provides for cooperation in exchanging information that is necessary for enforcement each of the signatory’s tax laws.

The DOJ and the IRS readily agreed. Then, the DOJ filed a petition in the Court asking for it to grant the IRS a permission to issue John Doe Summonses in response to the FTA’s request for help.

Finnish US Bank Accounts: Affected US Financial Institutions

The IRS Summonses specially target persons who reside in Finland and have Bank of America, Charles Schwab or TD Bank payment cards linked to bank accounts located outside of Finland. It is important to note that the DOJ does not allege that Bank of America, Charles Schwab or TD Bank violated any US or Finnish laws with respect to these accounts.

Finnish US Bank Accounts: Information Targeted by the IRS John Doe Summonses

The IRS John Doe Summonses seek the identities of Finnish residents who have payment cards linked to bank accounts located outside of Finland so that the Finnish government can determine if those persons have complied with Finnish tax laws.

Finnish US Bank Accounts: Foreign Individuals With Secret US Bank Accounts Are Not Safe from Disclosure to Their Governments

The recent IRS John Doe summonses concerning Finnish US bank accounts is another indication that foreign individuals with secret US bank accounts are not immune from the disclosure of these accounts to their governments at home. In fact, the US government will cooperate with requests for such information, at least from friendly governments.

“The Department of Justice and the IRS are committed to working with the United States’ international treaty partners to identify and stop individuals using hidden offshore accounts to evade tax laws,” said Principal Deputy Assistant Attorney General Richard E. Zuckerman of the Justice Department’s Tax Division. “The United States does not tolerate offshore tax evasion, nor does it sanction tax evasion committed through U.S. financial institutions.”

This cooperation also stems from the desire to somehow thank the foreign government for their prior cooperation with the IRS tax enforcement efforts that targeted (and continue to target) US taxpayers with undisclosed foreign bank accounts. “Our continued success in combating offshore tax noncompliance has been helped by the assistance we receive through the network of tax treaties around the globe,” said IRS Commissioner Charles Rettig. “Yesterday’s effort reflects that the U.S. will return this help by working under the law with tax administrators in other nations to help them in their fight against tax evasion and avoidance. A global economy should not be allowed to serve as a possible vehicle for tax evasion in any country.”

Sherayzen Law Office has predicted in the past that, after FATCA, the global tax enforcement will become tighter and more cooperative. Our predictions turned out to be correct.