Seattle FBAR Lawyer | IRS FATCA International Tax Attorney

I recently received a phone call from a person who was looking for a Seattle FBAR lawyer online and found my website. He asked me whether I can help him even though Sherayzen Law Office is based in Minneapolis, Minnesota. I responded to him: “yes, I can help you”.

This conversation brought to light an important topic of who should be considered a Seattle FBAR Lawyer and why an international tax lawyer based in Minneapolis can help a client in Seattle with FBAR issues.

Seattle FBAR Lawyer Definition: Legal FBAR Services Provided in Seattle, Washington

There are two categories of lawyers that fit the term Seattle FBAR Lawyer. The first category consists of US international tax lawyers who reside in Seattle and offer FBAR services to the residents of Seattle. The second category is comprised of US international tax lawyers who reside outside of Seattle but offer FBAR services to the residents of Seattle.

The first category is clear – if a lawyer resides in Seattle and offers FBAR services, he is considered to be a Seattle FBAR Lawyer. The question is: why is a lawyer who resides outside of Seattle still considered a Seattle FBAR lawyer? The answer lies in the legal nature of FBARs. FBAR is a federal information return, not a local requirement of Seattle or the State of Washington. This means that any licensed US international tax lawyer can offer FBAR services in any of the 50 states and the District of Columbia irrespective of his physical location. This is why a lawyer who resides in Minneapolis can offer FBAR legal services in Seattle with the same ease as a lawyer who resides in Seattle.

Seattle FBAR Lawyer Must Be US International Tax Lawyer

It should be emphasized that, while the residence of a Seattle FBAR Lawyer is not relevant, his area of practice is highly important. A Seattle FBAR lawyer must be an international tax lawyer – i.e. a lawyer who not only knows how to complete FBARS, but who has profound knowledge of US international tax law and the place the FBARs occupy in this law.

This emphasis is based on the fact that FBAR is only a small part of a much larger area of US international tax law. Indeed, there is a deep and complex relationship between the FBAR and international tax law that determines the legal position of a client and the potential voluntary disclosure strategies associated with delinquent FBARs.

This is why your Seattle FBAR lawyer should have deep knowledge of and extensive experience in both FBARs and all related US international tax laws and regulations.

Sherayzen Law Office Can Be Your Seattle FBAR Lawyer

Sherayzen Law Office is an international tax law firm that specializes in FBARs and international tax law. Our legal and accounting team has both: a profound knowledge of this area of law and extensive experience in helping clients with international tax law issues, including offshore voluntary compliance with respect to delinquent FBARs. We have helped hundreds of US taxpayers worldwide with their FBAR issues and we can help You!

Contact Sherayzen Law Office today to schedule Your Confidential Consultation!

Seattle FBAR Attorney | FATCA International Tax Lawyer

Due to Seattle’s proximity to Canada and a large amount of foreign professionals employed by high-tech firms (especially Microsoft), there is a large number of residents of Seattle, Washington, who have an obligation to report their foreign accounts. The great majority of these people need the assistance of professional Seattle FBAR attorney, but they find it difficult to decide who to retain. Often, they find that the attorney who they like lives outside of Seattle (for example, in Minneapolis) and they are not sure if they should prefer him over local Seattle FBAR Attorneys. This short essay is devoted to defining the term Seattle FBAR Attorney and the description of the main criteria which should guide you in retaining your Seattle FBAR Attorney.

Seattle FBAR Attorney: Definition

The term Seattle FBAR Attorney includes two groups of FBAR attorneys. First, all of the FBAR Attorneys who reside in Seattle, Washington, should be considered Seattle FBAR Attorneys.

The second group includes all FBAR Attorneys who reside outside of Seattle but offer their FBAR services to the residents of Seattle. Hence, the geographical location of your FBAR Attorney does not actually matter, only the geographical scope of his FBAR services.

Why is this case? The answer is relatively simple – FBAR is a federal compliance requirement. This means that neither the State of Washington nor the city of Seattle have anything to do with it.

Seattle FBAR Attorney: Knowledge of International Tax Law and FBARs is the Key Criteria for Retainer

Now that we know who is considered to be a Seattle FBAR Attorney, we can turn to the key criteria for choosing the right Seattle FBAR Attorney. There are two main considerations in choosing your FBAR Attorney: professional and personal.

The professional criteria consists of the requirement that your Seattle FBAR Attorney be an international tax lawyer with a lot of experience working with FBAR and FBAR-related issues.
It is not enough for your attorney to simply know what the FBARs are and how to prepare them. FBAR issues are often deeply intertwined with other US international tax requirements that determine a taxpayer’s legal and tax positions. Therefore, your Seattle FBAR Attorney must have profound knowledge of other related international tax law issues, regulations and compliance requirements.

In addition to the knowledge of the subject-matter (i.e. “objective criteria”), there is also a subjective criteria – do you feel he is devoted to your case. The issue of trust is the most important consideration here – both the client and the attorney will feel frustrated with the case if there is a deep distrust between them. This distrust may have a great influence on the outcome of the case.

Thus, in retaining your Seattle FBAR Attorney, you need to be looking for an international tax attorney who satisfies both criteria.

Seattle FBAR Attorney: Means of Communication is Not an Issue

Is there a difference between the ability to communicate with an out-of-state Seattle FBAR Attorney and a local one? Should this issue become part of the retainer criteria?

The answer is “no”: the objective ability to communicate (i.e. the availability of the modes of communication, rather than an attorney’s personal attitude toward communicating with a client) is not an issue in retaining a Seattle FBAR Attorney. The development of modern communications technology has eliminated the entire advantage of retaining a local Seattle FBAR Attorney. Even if your attorney resides in Seattle, almost all of your communication with him is going to be through email, telephone and regular mail – i.e. the same as if your attorney resides in Minneapolis. The person-to-person meetings are now easily replaced by a video Skype conference.

Obviously, personal subjective ability (i.e. availability and readiness to communicate with his clients) of a Seattle FBAR Attorney (irrespective of where he actually resides) to communicate with his clients is part of the subjective criteria for the retainer already discussed above.

Contact Sherayzen Law Office to Retain Your Seattle FBAR Attorney

Based on the analysis above, Sherayzen Law Office should be one of the preferred choices in your search for a Seattle FBAR Attorney. Sherayzen Law Office holds a leading position in the world on FBAR compliance due to its highly-experienced international tax team, headed by its founder Attorney Eugene Sherayzen. We have helped our clients throughout the world with FBAR compliance and all related international tax issues, including voluntary disclosure of foreign accounts under the IRS Offshore Voluntary Disclosure Program, Streamlined Domestic Offshore Procedures, Streamlined Foreign Offshore Procedures, Delinquent FBAR Submission Procedures, Delinquent International Information Return Submission Procedures and Reasonable Cause Disclosures (also known as “noisy disclosures”).

This is why, if you are looking for a Seattle FBAR Attorney, you should contact Sherayzen Law Office, Ltd. today to schedule Your Confidential Consultation!

FBAR Criminal Penalties


Potentially, a person who willfully fails to file an FBAR or files a false FBAR may be subject to:

  • A prison term of up to 10 years
  • Criminal penalties of up to $500,000
  • or both

When it comes to penalties, FinCEN Form 114 formerly Form TD F 90-22.1, Report on Foreign Bank and Financial Accounts (commonly known as FBAR), is one of the most severe forms ever issued by the U.S. Department of the Treasury.

In addition to a rich arsenal of civil penalties, the FBAR is also armed with criminal penalties that U.S. taxpayers may face in cases of willful non-compliance with the FBAR regulations.  The two most common cases for criminal prosecution are willful failure to file an FBAR and willful filing a false FBAR, especially when combined with potential tax evasion.

The authority for the severe criminal penalties can be found in 31 U.S.C. § 5322.  This means that, potentially, a person who willfully fails to file an FBAR or files a false FBAR may be subject to a prison term of up to 10 years, criminal penalties of up to $500,000 or both potentially, a person who willfully fails to file an FBAR or files a false FBAR may be subject to a prison term of up to 10 years, criminal penalties of up to $500,000 or both

With the mountain of information that the IRS recently accumulated as a result of the 2009 OVDP, 2011 OVDI and, now, 2012 OVDP voluntary disclosure programs, one should expect a dramatic rise in FBAR enforcement. This, of course, means that we are likely to witness the equivalent rise in FBAR audits and criminal prosecutions.

Contact Sherayzen Law Office for FBAR Help

If you have undisclosed foreign accounts and you are subject to the FBAR requirements, contact Sherayzen Law Office immediately.  Our experienced international tax firm will thoroughly review your case, analyze the available options in a responsible and creative way, create a case plan, draft and complete the necessary legal and tax documents and forms, and rigorously represent your case before the IRS.

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