offshore voluntary disclosure lawyers Minneapolis

Streamlined Foreign Offshore Procedure

/in , /by

One of the most dramatic changes to the voluntary disclosure process made by the IRS on June 18, 2014, was the complete revamping of the Streamlined Foreign Offshore Procedure. As long as the taxpayer can honestly certify that his prior violations of U.S. tax laws were non-willful, the Streamlined Foreign Offshore Procedure offers a unique opportunity for such a taxpayer to bring his tax affairs with respect to foreign accounts and other offshore assets into complete compliance with the U.S. tax rules with potentially no penalties. In this article, I am going to outline the Streamlined Foreign Offshore Procedure and discuss why it is important to take advantage of it as soon as possible.

Old Streamlined Foreign Offshore Procedure

The Streamlined Foreign Offshore Procedure already existed prior to June 18 changes. However, while it offered a no penalty solution to U.S. taxpayers residing overseas, it also imposed severe limitations preventing the great majority of these taxpayers from qualifying to participate in the Streamlined Foreign Offshore Procedure.

The most difficult conditions were the $1,500 additional tax liability threshold and the risk assessment process (to comply with the “simple return” rule). Further complications would arise from the failure to timely file original tax returns.

2014 Changes to Streamlined Foreign Offshore Procedure

It is precisely these difficult requirements that were removed by the IRS in June of 2014, thereby opening up a tremendous opportunity to U.S. taxpayers residing overseas: the $1,500 tax limit was gone, the risk assessment process was gone, and the importance of timely filed U.S. tax returns was also downgraded. Instead, the IRS created a new advantageous (to U.S. taxpayers) Streamlined Foreign Offshore Procedure with simplified eligibility requirements.

If these requirements are met, a U.S. taxpayer residing overseas can now avoid the imposition of all FBAR penalties if he follows the Streamlined Foreign Offshore Procedure for filing amended tax returns and delinquent FBARs.  Moreover, as an additional bonus, the IRS is stating that it will waive all failure-to-file and failure-to-pay penalties, accuracy-related penalties, and information return penalties.

There are some limitations on this generous gift. Any previously assessed penalties with respect to those years, however, will not be abated. Furthermore, as with any U.S. tax return filed in the normal course, if the IRS determines an additional tax deficiency for a return submitted under these procedures, the IRS may assert applicable additions to tax and penalties relating to that additional deficiency.

Since Streamlined Foreign Offshore Procedure offers such tremendous benefits to U.S. taxpayers who reside outside of the United States, it is important to make sure that all of the eligibility and filing requirements are met.

Streamlined Foreign Offshore Procedure: Eligibility requirements

There are three main eligibility requirements for participation in the Streamlined Foreign Offshore Procedure. First, the taxpayer must meet the applicable non-residency requirement. Here is the first caveat, for joint return filers, both spouses must meet the applicable non-residency requirement. Different rules apply to taxpayers who are U.S. citizens and U.S. permanent residents than to those taxpayers who do not fall into these categories.

The second requirement of the Streamlined Foreign Offshore Procedure is that the taxpayer violated the applicable U.S. tax requirements non-willfully – i.e. the taxpayer failed to report the income from a foreign financial asset and pay tax as required by U.S. law, and may have failed to file an FBAR (FinCEN Form 114, previously Form TD F 90-22.1) with respect to a foreign financial account, and such failures resulted from non-willful conduct.

The third requirement of the Streamlined Foreign Offshore Procedure is that the participating taxpayer is not subject to an IRS civil examination or an IRS criminal investigation.  Two important points here – it does not matter whether the examination relates to undisclosed foreign financial assets and it does not matter whether the examination involves any of the years subject to the voluntary disclosure.  In either case,  the taxpayer will not be eligible to use the Streamlined Foreign Offshore Procedure.

In reality, there is a more obscure fourth requirement that there is a valid Taxpayer Identification Number (TIN), but this issue can be solved by enclosing a completed ITIN application with the disclosure package under the Streamlined Foreign Offshore Procedure.

Filing Requirements Under the Streamlined Foreign Offshore Procedure

There are five main filing requirements that must be met in order to comply with the Streamlined Foreign Offshore Procedure.

The first filing requirement under the Streamlined Foreign Offshore Procedure is that, for each of the most recent 3 years for which the U.S. tax return due date (or properly applied for extended due date) has passed, the taxpayer must file delinquent or amended tax returns, together with all required information returns (e.g., Forms 3520, 5471, and 8938). Specific procedures must be followed in the preparation of these returns.

The second filing requirement under the Streamlined Foreign Offshore Procedure is that, for each of the most recent 6 years for which the FBAR due date has passed, the taxpayer must file delinquent FBARs according to the FBAR instructions and include a statement explaining that the FBARs are being filed as part of the Streamlined Filing Compliance Procedures. The taxpayer is required to file these delinquent FBARs electronically at FinCEN. Detailed instructions must be followed to file these FBARs properly.

The third filing requirement under the Streamlined Foreign Offshore Procedure is the submission of the payment of all tax due as reflected on the tax returns and all applicable statutory interest with respect to each of the late payment amounts. The taxpayer’s TIN must be included on the check.

The fourth filing requirement under the Streamlined Foreign Offshore Procedure is the submission of any requests for relief for failure to timely elect deferral of income from certain retirement or savings plans where deferral is permitted by an applicable treaty.  Specific additional requirements apply to this request (especially, in the Canadian RRSP context).

Finally, the fifth filing requirement under the Streamlined Foreign Offshore Procedure is the most important part of this application – completed and signed “Certification by U.S. Person Residing Outside of the U.S.” (as of July 4, 2014, this is still in draft format but the final version should appear soon).

This is the most important legal document in the Streamlined Foreign Offshore Procedure. This is the statement that certifies that the taxpayer: (1) is eligible for the Streamlined Foreign Offshore Procedures; (2) that all required FBARs have now been properly filed; and (3) that the failure to file tax returns, report all income, pay all tax, and submit all required information returns, including FBARs, resulted from non-willful conduct. I cannot emphasize enough the importance of contacting your international tax attorney prior to submitting this document to the IRS.

The taxpayer must submit the original signed statement as well as attach copies of the statement to each tax return and information return being submitted through these procedures.

Streamlined Foreign Offshore Procedure: Some Considerations

While participation in the Streamlined Foreign Offshore Procedure may offer tremendous benefits to U.S. taxpayers who reside outside of the United States, it is important to understand that this may not be a simple process and all considerations should be taken into account. From the legal determination of whether the residency requirements are met to the very complicated legal decision on whether the “non-willful” determination applies, Streamlined Foreign Offshore Procedure involves significant legal analysis.

Based on my extensive experience, I believe that the great majority of the U.S. taxpayers who are currently not in compliance with the FBAR requirements are non-willful at heart. However, it is important to make sure that the legal case supports this finding – i.e. the facts of the case should support the determination of legal non-willfulness.

I strongly advise against making such determination without the help of an international tax lawyer. You need an attorney who can look at your case objectively and with a “cool head”, and make such determination based on his experience and knowledge of law.

Finally, it is essential to understand that there is no guarantee that Streamlined Foreign Offshore Procedure will be available even in half a year in the same format.  The IRS reserved the power to change the rules regarding  Streamlined Foreign Offshore Procedure at any point.  This is why it is so important to act fast to make sure that you are able to take advantage of this unique opportunity.

Contact Sherayzen Law Office for Professional Help with Your Participation in the Streamlined Foreign Offshore Procedure

If you have undisclosed foreign accounts, contact Sherayzen Law Office for a professional analysis of your voluntary disclosure options. Our international tax law firm has helped hundreds of U.S. taxpayers worldwide and we can help you.

Contact Us to Schedule Your Confidential Consultation!

New 2014 OVDP Update: Introduction

/in , /by

On June 18, 2014, the IRS made a major upgrade to its existing Offshore Voluntary Disclosure Program (“OVDP”).  The new OVDP will now be called 2014 OVDP.  While the changes to the OVDP rules are significant, the new rules regarding the Streamlined Procedure are maybe even more important.

Here is a summary of the 2014 changes to the 2012 OVDP:

2014 OVDP Update: New Miscellaneous 50% Penalty

The IRS added a new FAQ 7.2 which imposes a 50% offshore penalty on taxpayers who participate in the OVDP if: either a foreign financial institution at which the taxpayer has or had an account or a facilitator who helped the taxpayer establish or maintain an offshore arrangement has been publicly identified as being under investigation or as cooperating with a government investigation.

I believe that this new penalty is a direct consequence of the successful IRS and DOJ efforts to enforce FATCA overseas, particularly the Swiss Program for Banks.  Read this article for more information.

2014 OVDP Update: Elimination of the Reduced Penalty Structure Under FAQ 52 and 53

The reduced 12.5% and 5% penalty structure under former FAQs 52 and 53 has been eliminated due to the expansion of the Streamlined Filing Compliance Procedures. Rather, the new Streamline Offshore Procedure will take over. Special procedures apply to the taxpayer who already entered the OVDP program. I will provide more details in a later article.

2014 OVDP Update: Elimination of FAQ 17 and 18; Procedure is Still Available

This change is just the clarification of the already existing rules. While technically both rules are eliminated, the taxpayer can still use both rules.  Read this article with respect to the Delinquent FBAR Submission Procedures (replacing FAQ 17). I will provide the FAQ 18 details in a later article.

2014 OVDP Update: New Streamline Procedure Rules – US Residents are Included

It finally happened – taxpayers residing in the United States now have the option to enter the streamline procedures which were first announced on September 1, 2012. Other major changes include the elimination of the $1,500 tax threshold and elimination of the risk assessment process. I will provide more details in a later article.

2014 OVDP Update: Updated Streamlined Foreign Offshore Procedures

The IRS greatly expanded the eligibility requirements for the U.S. taxpayers who reside overseas.  Read this article on the Streamlined Foreign Offshore Procedures.

2014 OVDP Update: Major Changes to FAQ 31-41

These are the important changes that the 2014 OVDP Update made to the calculation of the asset base to which the offshore penalty will apply.

2014 OVDP Update: New Pre-Clearance Procedural Change under FAQ 23

Now, the IRS wants to know more information about you before granting the pre-clearance to apply for the OVDP. The 2014 OVDP Update greatly expands the information required to be submitted under FAQ 23. I will provide more details in a later article.

2014 OVDP Update: Offshore Penalty Must Be Paid With Submission of the OVDP Package

This is a major 2014 OVDP Update to FAQ 7. Now the Offshore Penalty must be paid with the submission of the OVDP Package. Again, I will provide more details in a later article.

Other 2014 OVDP Updates: Procedural Changes

The rest of the 2014 OVDP Update changes are more procedural in nature, but may have real substantive impact. Among them, the changes in the FAQ 25 (requiring the submission of account statements irrespective of the size of the disclosure), new OVDP Letter, new OVDP Letter Attachment, and other technical changes. Once again, I will provide more details in a later article.

Contact Sherayzen Law Office for a Professional Advice Regarding Your Offshore Voluntary Options

The new 2014 OVDP Update presents new opportunities mixed with new traps. It is important to make sure that you get expert advice regarding your Offshore Voluntary Disclosure. Contact the experienced tax law firm of Sherayzen Law Office. We have helped clients throughout the world and we can help you.

Contact Us to Schedule Your Confidential Consultation!

Swiss Bank Letters Cause Legal Complications for U.S. Taxpayers

/in , /by

The Swiss Bank letters continue to pour into the mailboxes of U.S. taxpayers with bank and financial accounts in Switzerland as the April 30th deadline approaches for many Swiss banks that participate in the ongoing U.S. Department of Justice (“DOJ”) The Program for Non-Prosecution Agreements or Non-Target Letters for Swiss Banks (the “Program”). In an earlier article, I already discussed what the Swiss Bank letters contain, and the importance of the need for the comprehensive analysis of the offshore voluntary disclosure options. In this article, I would like to concentrate on another aspect of Swiss Bank letters – the top three legal complications that these Swiss Bank letters cause to U.S. taxpayers.

1. Swiss Bank Letters Provide Notice of Non-Compliance with the FBAR and Other International Tax Compliance Requirements

The first problem with the Swiss Bank Letters is that they provide the notice of non-compliance with the FBAR and other important international tax requirements (depending on the Bank, it can include such Forms as 5471, 8865, 926, 3520 and so on). The issue here is not so much that the Banks are making their U.S. taxpayers aware of the U.S. tax reporting requirements, but the context in which this is done.

If the Swiss Bank letters were to arrive upon the opening of a Swiss bank account or, at least, prior to the Program, it would be a huge benefit to the unsuspecting U.S. taxpayers. However, this is not the case. Rather, the notice of these requirements is given after a potentially substantial period of non-compliance with these requirements.

Moreover, the Swiss Bank letters provide a notice of non-compliance in the context of forced disclosure under the terms of the Program. Such notice has a potential to taint disclosures outside of the OVDP with the same air of the taxpayer being “forced” to disclose as opposed to doing it voluntarily (at the very least, the argument that the taxpayer is doing this disclosure without any pressure from the IRS definitely loses credibility).

Finally, the Swiss Bank letters provide a Notice of non-compliance with requirements, without even attempting to educate their audience about these requirements or suggesting to contact an international tax attorney to see if these taxpayers are really in violation of these requirements. For example, how would a taxpayer know whether Form 3520 requirement actually applies to him?

2. Swiss Bank Letters Start the Clock for Disclosure Under Extreme Time Pressure

The second problem with Swiss Bank letters is that they start the clock for the taxpayer to be able to disclosure his accounts voluntarily under an enormous time pressure. A lot of the banks that send these Swiss Bank letters will disclose by April 30, 2014. This means that the taxpayers who receive the Notice today have less than two months to disclose their accounts voluntarily before they run an enormous risk of prior disclosure of their accounts by Swiss banks to the IRS (with the effect on potentially preventing these taxpayers from entering into the OVDP). Even the taxpayers who received notices at the end of last year and January of this year are not much better off.

This is a very big problem, because time pressure may not allow the taxpayers to choose the right type of voluntary disclosure. Moreover, even if they wanted to do one type of disclosure rather than another, their options may be limited due to insufficient time to implement the strategies necessary to make their preferred choice of the voluntary disclosure successful.

3. Swiss Bank Letters May Mislead U.S. Taxpayers in Believing that OVDP is the Only Option

Swiss Bank letters uniformly advise their clients to enter into the OVDP without ever mentioning any alternatives. It is as if the assumption of willful failure to file FBARs is already written into the Swiss Bank letters. Theoretically, one could even argue that, by advising taxpayers to enter the OVDP instead of consulting an international tax attorney about their options, some of the Swiss Bank letters over-step their boundaries and enter the world of giving legal advice without a license.

At the practical level, the problem is even more profound. The Swiss Bank letters have the potential to mislead U.S. taxpayers with undisclosed accounts into believing that OVDP is the only option available to them and they have to take this option because their bank will soon disclose their accounts to the IRS. While, undoubtedly, OVDP may be the best option in many cases, this may not be true in other cases. The problem is that, the way Swiss Bank letters are drafted, the U.S. taxpayers may never be even given the choice.

Contact Sherayzen Law Office for Help If You Received Swiss Bank Letters

Sherayzen Law Office is here to help you with the voluntary disclosure of your Swiss bank and financial accounts. Owner Eugene Sherayzen is an international tax attorney and expert in this field who can analyze the facts of your case and explain to you the available voluntary disclosure options. After you choose the voluntary disclosure option, our firm can prepare all legal documents and tax forms required for your voluntary disclosure, fully implement the ethically available strategies and rigorously defend your position against the IRS.

Contact Us for a Confidential and Privileged Consultation!

OVDP International Tax Attorney: Letters from Swiss Banks & OVDP

/in , /by

This is a natural question for an OVDP International Tax Attorney: in light of the ongoing U.S. Department of Justice (“DOJ”) The Program for Non-Prosecution Agreements or Non-Target Letters for Swiss Banks (the “Program”), should every U.S. taxpayer with undisclosed Swiss accounts enter the Program?

As everything in international tax law, the answer of whether you should enter the OVDP program (now closed) after receiving a letter from the Swiss Bank is not that simple and depends (as any good OVDP International Tax Attorney will tell you) on the particular circumstances of your case. The article below is not intended to give legal advice, but it is merely a discussion of various possibilities – please contact Mr. Eugene Sherayzen, an experienced international tax attorney of Sherayzen Law Office for professional advice with respect to your undisclosed foreign accounts.

OVDP International Tax Attorney: Letters from Swiss Banks

Ever since more than a hundred banks officially announced (and a lot of private banks did so unofficially) that they will enter the Program, U.S. taxpayers with undisclosed Swiss bank accounts have received letters from their Swiss banks asking the taxpayers whether they are in compliance with U.S. tax laws, whether they have filed their FBARs (Report of Foreign Bank and Financial Accounts, currently Form FinCen 114 (formely TD F 90-22.1))and, if not, whether they entered the IRS Offshore Voluntary Disclosure Program (OVDP).

Indeed the emphasis in all of the letters has been on the OVDP without any regard to the individual circumstances of the taxpayers and despite the fact that many of these taxpayers learned about the existence of the FBARs from the very letters from their Swiss banks.

OVDP International Tax Attorney: Common Chorus to Join OVDP

It is not only the Swiss banks that are urging these taxpayers to enter the OVDP. The IRS is also very eager to see as many people enter the OVDP as possible. Shockingly, the great majority of accountants readily take on the legal (not accounting) issue of whether a client should enter the OVDP. The accountants herd their clients into the OVDP without ever discussing the consequences of doing so or any other legal alternatives.

The end result of this common stance has been to convince the terrified taxpayers that OVDP is the only route available to them irrespective of their circumstances, whether the FBAR non-compliance was willful or non-willful, whether they have reasonable cause for the delayed filing of their FBARs or not, whether they owe any taxes or not, and so on.

OVDP International Tax Attorney: OVDP is Option #1

Of course, as an OVDP International Tax Attorney, I agree that there is no doubt that OVDP is Option #1 that must be considered by U.S. taxpayers who received a letter from their Swiss banks However, being Option #1 does not mean the only option and does not mean that it should be automatically followed.

Moreover, even under the OVDP, there are many issues, strategies and possibilities that must be explored by your OVDP International Tax Attorney.

Undoubtedly, OVDP has tremendous benefits to offer to U.S. taxpayers with willful non-compliance and who may be facing realistic criminal penalties. On the other hand, the calculation becomes much more complicated when your client simply did not know about the FBARs and the IRS is not likely to be able to sustain its burden of proof on the willfulness issue.

Comprehensive Legal Analysis of the Voluntary Disclosure Alternatives Must Be Considered

In all cases, but even more so in the non-willful cases, a very complex calculation and cost-benefit analysis must be conducted by your OVDP International Tax Attorney, comparing traditional FBAR penalty structure with the OVDP penalty structure. Outside factors, such as time, legal fees, complexity of the issues, impact on tax returns, appeal possibilities, and many others, should be considered your OVDP International Tax Attorney. Once all factors are considered, the Attorney should advise you on the available Voluntary Disclosure alternatives and the probability of success.

Only then, armed with this knowledge and based on the analysis of a good OVDP International Tax Attorney, should a U.S. taxpayer with undisclosed Swiss accounts make his decision.

Contact Sherayzen Law Office for Professional Legal and Tax Help With the Voluntary Disclosure of Your Foreign Accounts

The point of this article is not to diminish the value of the OVDP, but to argue that all U.S. taxpayers with undisclosed foreign accounts should be given a chance to consider all of their voluntary disclosure options based on the comprehensive analysis of their particular circumstances.

This is precisely what Sherayzen Law Office experienced international tax firm can do for you. We will thoroughly analyze the facts of your case, assess the potential FBAR and OVDP penalties and tax liabilities, analyze the voluntary disclosure alternatives, create a comprehensive voluntary disclosure plan for you, and implement this plan (including the preparation of all legal documents and tax forms).

Contact Us to schedule a Confidential Consultation with an experienced International Tax Attorney.

OVDP Foreign Accounts Lawyers: Swiss Banks Disclosure Deadline on April 30, 2014

/in , /by

As many OVDP Foreign Accounts Lawyers know, April 30, 2014 is a crucial deadline for the U.S. Department of Justice (“DOJ”) The Program for Non-Prosecution Agreements or Non-Target Letters for Swiss Banks (the “Program”). By this date, numerous Swiss banks will have to disclose the names of US accountholders, account balance information, and various other data with respect to U.S. accountholders.

OVDP Foreign Accounts Lawyers: What Banks Will Disclose U.S. Taxpayers by April 30, 2014

The list of Swiss Banks who will disclose their U.S. taxpayers to the IRS and DOJ by April 30, 2014 is very large and includes prominent banks such as:

Aargauische Kantonalbank
Acrevis Bank AG
AEK Bank 1826
Appenzeller Kantonalbank
Baloise Bank SoBa
Bank am Bellevue
Bank Coop AG
Banque Cantonale de Fribourg
Banque Cantonale de Genève
Banque cantonale du Jura
Banque cantonale du Valais
Banque Cantonale Neuchâteloise
Banque Cantonale Vaudois
Banque Privee Edmond de Rothschild
Basellandschaftliche Kantonalbank
Berner Kantonalbank
Cembra Money Bank AG
Cornèr Banca SA
Edmond de Rothschild Group
EFG International AG
Glarus Bank
Graubündner Kantonalbank
Hyposwiss Privatbank Zurich AG
Hyposwiss Private Bank Geneve SA
Hypothekarbank Lenzburg
Linth Bank
Lombard Odier & Cie.
Luzerner Kantonalbank
Migros Bank
Nidwaldner Kantonalbank
Piquet Galland & Cie SA
Post Finance
Raiffeisen
Rothschild Bank AG, Zurich
Saanen Bank
Schaffhauser Kantonalbank
Schwyzer Kantonalbank
St. Galler Kantonalbank
Ticino Cantonal Bank
Union Bancaire Privee
Valartis Bank (Switzerland)
Valiant Holding AG
Vontobel Holding AG
VP Bank (Switzerland)
Walliser Kantonalbank
Zuger Kantonalbank

Note: this is just a selective list – many other banks that are not named here are participating in the Program. This is particularly true for many private banks that are not required to disclose publicly whether they are participating in the Program.

OVDP Foreign Accounts Lawyers: Two Cantonal Banks and Other Category 1 Banks Excluded from the Program

The US Department of Justice (DOJ) previously launched investigations against two other Swiss cantonal banks, such as Baser Kantonalbank and Zürcher Kantonalbank. These banks are classified as Category 1 banks and will not be allowed to enroll in the Program. Similarly, otehr Category 1 banks cannot participate in the program Credit Suisse, Julius Baer, Pictet, HSBC Privatbank, Liechtensteinische Landesbank, Bank Leumi, Bank Hapoalim, Bank Mizrahi, Rahn & Bodmer, Bank Wegelin, Bank Frey, Neue Zürcher Bank.

OVDP Foreign Accounts Lawyers: Letters from Banks

As part of their “voluntary disclosure” under the Program, the Swiss Banks have already sent out letters to the majority of their U.S. account holders. These letters are not mere warnings (though, they also are exactly that to many unsuspecting U.S. taxpayers) to U.S. taxpayers with undisclosed Swiss accounts, but they are also a way for the Swiss Banks to minimize their penalty exposure (because, in calculating their own penalty base, Category 2 banks do not have to count the bank accounts which are already disclosed to the IRS).

OVDP Foreign Accounts Lawyers: What Does April 30, 2014 Mean for U.S. Taxpayers With Undisclosed Foreign Accounts

As most OVDP Foreign Accounts Lawyers indicate, April 30, 2014, marks a very important deadline for U.S. taxpayers with undisclosed foreign accounts in Switzerland. The reason is found in the Offshore Voluntary Disclosure Program (“OVDP”) acceptance rules.

The rules basically state that if the IRS receives the information about undisclosed foreign accounts from a third party before U.S. owner of these accounts enters the OVDP program, then the IRS will likely reject (or, as it was in the case with some OVDP participants last year – eject such U.S. owner from the OVDP) such U.S. owner’s application to participate in the OVDP program.

Therefore, OVDP Foreign Accounts Lawyers advise their clients that a very important and the most official route to voluntary disclosure will simply become completely closed to many U.S. taxpayers who fail to enter OVDP and disclose their Swiss accounts prior to April 30, 2014.

Of course, it is important to note, that it is possible that some of the Swiss banks have already disclosed such unreported accounts owned by U.S. taxpayers and many more are likely to do it in advance of the April 30, 2014, deadline.

In such case, U.S. taxpayers who either hold or previously held undisclosed bank accounts at any of the Swiss cantonal banks eligible for enrollment in the Program, or any bank already under investigation, may face substantial civil and potential criminal penalties if they do nothing or if their cases are not handled properly.

Therefore, it is imperative for U.S. taxpayers with undisclosed Swiss bank and financial accounts to contact OVDP Foreign Accounts Lawyers who specializes in the OVDP disclosure of foreign accounts.

Contact Sherayzen Law Office for Professional Help with Undisclosed Swiss Accounts

Experienced OVDP (program now closed) foreign accounts lawyer Eugene Sherayzen of Sherayzen Law Office, Ltd. can help you with all of your voluntary disclosure issues. Our experienced tax law office will thoroughly review your case, estimate your existing tax and FBAR liability in the United States, identify the available voluntary disclosure options, prepare your voluntary disclosure package (including all legal documents and tax forms) and rigorously defend your interests during your negotiations with the IRS.

Contact Us Now to schedule a Confidential Consultation as soon as possible.