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Denver FBAR Lawyer | Foreign Accounts Tax Attorney

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Finding a good Denver FBAR Lawyer is not easy, especially if you do not know what exactly Denver FBAR Lawyer means. In this essay, I will define what lawyers fit into the definition of a Denver FBAR Lawyer and why you should retain the services of my firm, Sherayzen Law Office, Ltd.

Denver FBAR Lawyer Definition: Legal FBAR Services Provided in Denver, Colorado

Some of the readers may be surprised to learn that the definition of a Denver FBAR Lawyer is not limited by the physical presence of the lawyer. Rather, a Denver FBAR Lawyer is any international tax lawyer who offers legal and tax services related to FBARs in Denver, Colorado. This means that your FBAR lawyer can reside in Minneapolis and still be considered as Denver FBAR Lawyer even if he has never been to Denver.

Why is that? The reason is simple: FBAR is federal law, not state law; i.e. the city of Denver and the State of Colorado have absolutely nothing to do with the implementation of FBAR. Since there is no local input, the physical residence of your lawyer gives you no advantage whatsoever when it comes to legal services related to FBARs.

Denver FBAR Lawyer Must Be an International Tax Lawyer

While the physical location of a your FBAR lawyer is irrelevant, his competence in FBARs and the US international tax law is an indispensable quality. It is important to understand that, in the great majority of cases, the FBAR issues are tightly intertwined with other international tax compliance requirements, and it is the interaction between the FBAR and other international tax issues that is relevant to the determination of a taxpayer’s legal position. This is why your Denver FBAR lawyer should be highly knowledgeable in other areas of international tax law in addition to FBARs.

Denver FBAR Lawyer: the Convenience of Communication

Perhaps, while the readers agree that the definition of a Denver FBAR lawyer should include any experienced international tax lawyer who provides FBAR-related services in Denver, they may still point to old belief of the ease of communication with a local lawyer. In essence, this myth holds that while an out-of-state FBAR lawyer may be more competent in international tax law, it is better to rely on a local FBAR lawyer because it would be easier to communicate with him.

This myth is simply incorrect, because it does not take into account the development modern communications technology and it incorrectly represents a client’s communication with their Denver FBAR lawyer.

The modern communications technology has virtually eliminated the entire advantage of retaining a local Denver FBAR Lawyer. Email, telephone, fax and Skype video conferences provide ample opportunities to communicate with your lawyer wherever he is and at any point of time. In fact, as an international tax lawyer, I have continuously relied on these means of communication to successfully represent all of my out-of-state clients, including Denver, Colorado. There has not been a single case where my geographical location was of any importance.

Furthermore, it is important to understand that, aside from the initial consultation (which can also be conducted on Skype or telephone), almost all of your communication with a local Denver FBAR lawyer will be through the same modern means of communication – email and telephone. This means that 98% of communication between you and your lawyer will be done in the same manner irrespective of whether he resides in Denver!

Sherayzen Law Office is a Top Choice for Your Denver FBAR Lawyer

Sherayzen Law Office occupies a leading position in the world on this subject with extensive knowledge and experience concerning all major relevant areas of international tax law including PFIC compliance, Subpart F rules, all types of US international reporting returns, US income tax returns (individual, partnership and corporate) for domestic and foreign persons, et cetera. Furthermore, this is one of the leading international tax law firms in the world with experience in all major IRS voluntary disclosure programs, including 2009 OVDP, 2011 OVDI, 2012 OVDP and 2014 OVDP (now closed).

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

Madison FBAR Attorney | FBAR FATCA OVDP IRS Lawyer

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Do you reside in Madison and have undisclosed foreign accounts? Are you searching for a highly-knowledgeable Madison FBAR Attorney to help you resolve this situation? Then, read this essay in order to understand who is considered to be a Madison FBAR Attorney and and why you should retain the services of my firm, Sherayzen Law Office, Ltd..

Madison FBAR Attorney: Geographical Location

There is a traditional preference among people to choose an attorney who lives in their city due to perceived communication problems with an attorney outside of their city. Also, often, the fact that their attorney is local sometimes gives an illusion of a better control over the case.

This is an incorrect view when it comes to a case that involves FBARs – in reality, the geographical location of a Madison FBAR Attorney does not have any impact on the attorney’s ability to conduct your FBAR case. The reason is that FBAR is federal law; the state of Wisconsin and the city of Madison have no impact over the implementation and enforcement of FBAR. This means that the physical location of a Madison FBAR Attorney does not affect the effectiveness of his legal representation of his clients in Madison or any other city.

Furthermore, the communication issue is a mythical problem in today’s world. The development of modern communications technologies has eliminated the entire advantage of retaining a local Madison FBAR Attorney. Even if your attorney lives and works in Madison, almost your entire communication with him is going to be through email, telephone and regular mail – i.e. the same as if your attorney resides in Madison. The infrequent person-to-person meetings can now be replicated through a video Skype conference.

Finally, retaining a local Madison FBAR Attorney has no impact on the control over the case by the client. It all depends on the personality of the attorney; a good attorney would maintain control over the legal side of the case, while allowing his client to make informed choices with respect to issues that require a client’s input (such as a personal preference for a voluntary disclosure path).

All of this analysis leads us to two important conclusions. First, a Madison FBAR Attorney is any attorney, irrespective of his residence, who offers his FBAR services in Madison. Second, the geographical location should not have influence over your decision to retain a Madison FBAR Attorney; the personality and, as will be explained below, the knowledge of your attorney is what really matters.

Madison FBAR Attorney: Knowledge of International Tax Law and FBARs is the Key

We are now approaching the key consideration that you should have in retaining a Madison FBAR Attorney: his knowledge of the subject matter.

The subject matter that your Madison FBAR attorney must know should be broader than just FBARs. Rather, he should know about FBAR, the place this form occupies within the US international tax system and how FBAR interacts with other US international tax compliance requirements, such as foreign income reporting, FATCA Form 8938, Form 8621, foreign business ownership information returns, et cetera. This profound knowledge of US international tax law should also include the knowledge of remedying past noncompliance, including the various voluntary disclosure options.

Thus, FBAR issues are often highly intertwined with the rest of the US tax laws and this interaction is what will make the real impact on your tax position in the United States. This is why your Madison FBAR Attorney should be highly knowledgeable in US international tax law in general, not just FBARs.

Madison FBAR Attorney: Contact Sherayzen Law Office

We are now ready to answer the main underlying question of this essay: who should you retain if you are looking for a highly-skilled Madison FBAR Attorney? While the actual choice is ultimately personal, based on the objective criteria, Sherayzen Law Office definitely should be a top candidate in your search.

Sherayzen Law Office is a leading tax firm in the area of FBAR compliance due to profound knowledge of the subject matter and extensive experience of dealing with FBARs and related issues including foreign income reporting, FATCA compliance (Form 8938), PFIC compliance (Form 8621), Subpart F rules, all types of US international reporting returns (3520, 3520-A, 5471, 8865, 8858, 926, et cetera), US income tax returns (individual, partnership and corporate) for domestic and foreign persons and other issues.

Furthermore, Sherayzen Law Office has helped hundreds of clients with their past FBAR noncompliance. In fact, this is one of the leading international tax law firms in the world with experience in all major IRS offshore voluntary disclosure programs, including 2009 OVDP, 2011 OVDI, 2012 OVDP and the still current (as of August of 2016) 2014 OVDP.

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

Philadelphia FBAR Attorney | Foreign Accounts Lawyers

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Are you looking for a highly-skilled Philadelphia FBAR Attorney? Then, you are among many Philadelphians who need to report their foreign accounts, but do not know how to find appropriate legal help. Often, they find the attorney that they like lives outside of Philadelphia and they are not sure if they should prefer him over local Philadelphia FBAR Attorneys. In this short article, I would like to address the issue of who is considered to be a Philadelphia FBAR Attorney and why you should retain the services of my firm, Sherayzen Law Office, Ltd. (Sherayzen Law Office).

Philadelphia FBAR Attorney: Geographical Location

From the outset, it is important to understand that the geographical location of a Philadelphia FBAR Attorney does not have any impact on the attorney’s ability to conduct your FBAR case. The reason for this statement lies in the fact that FBAR is federal law. The state of Pennsylvania and the city of Philadelphia have no influence whatsoever over the implementation and enforcement of FBAR. This means that the physical location of your Philadelphia FBAR Attorney does not affect the effectiveness of his legal representation of his clients in Philadelphia.

Furthermore, the development of modern communications technology has eliminated almost the entire advantage of retaining a local Philadelphia FBAR Attorney. Even if your attorney resides in Philadelphia, almost all of your entire 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.

All of this analysis leads us to two important conclusions. First, a Philadelphia FBAR Attorney is any attorney, irrespective of his residence, who offers his FBAR services in Philadelphia. Second, the geographical location should not have any impact on your decision to retain a Philadelphia FBAR Attorney.

Philadelphia FBAR Attorney: Knowledge of International Tax Law and FBARs is the Key

The conclusions from the first part of this essay point us now to the key consideration that you should have in retaining a Philadelphia FBAR Attorney: his knowledge of the subject matter.

What is this “subject matter”? Is it only limited to knowing the FBARs or is there something else a Philadelphia FBAR Attorney should know? Indeed, the subject matter that your attorney must know should not be limited to just how to file an FBAR. Rather, he should know about FBAR, the place this form occupies within the US international tax system and how FBAR interacts with other US international tax compliance requirements, such as foreign income reporting, Form 8938, Form 8621, foreign business ownership reporting returns (5471, 8865 and 8858), et cetera.

It is also important to understand that the FBAR issues are often highly intertwined with the rest of the US tax laws and this interaction is what will make the real impact on your tax position in the United States. This is why your Philadelphia FBAR Attorney should be highly knowledgeable in other areas of international tax law in addition to FBARs.

Philadelphia FBAR Attorney: Contact Sherayzen Law Office

We can now revert to the question we already posed at the beginning of the essay: who should you retain if you are looking for a highly-skilled Philadelphia FBAR Attorney. While the actual choice is ultimately personal, based on the objective criteria, Sherayzen Law Office should definitely occupy a top spot in your search.

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, that has been helping its clients throughout the world with FBAR and related international tax issues including foreign income reporting, FATCA compliance (Form 8938), PFIC compliance (Form 8621), Subpart F rules, all types of US tax information returns (3520, 3520-A, 5471, 8865, 8858, 926, et cetera), US income tax returns (individual, partnership and corporate) for domestic and foreign persons and other issues.

Furthermore, Sherayzen Law Office has helped hundreds of clients who are delinquent with respect to their FBAR and other US tax obligations. In fact, Sherayzen Law Office is one of the leading international tax law firms in the world with experience in all major IRS voluntary disclosure programs, including 2009 OVDP, 2011 OVDI, 2012 OVDP and 2014 OVDP now closed.

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

FBAR PFIC Reporting | FBAR Tax Attorney

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FBAR PFIC Reporting is an important issue for U.S. shareholders of passive foreign investment companies (“PFICs”). I will now briefly explore the FBAR PFIC Reporting requirement and when it applies to U.S. shareholders of a PFIC.

FBAR PFIC Reporting: FBAR Background

FinCEN Form 114, the Report of Foreign Bank and Financial Accounts, commonly known as FBAR, originally came into existence as a result of the 1970 Bank Secrecy Act. FBAR is one of the main and arguably the most important international tax requirement in the IRS. The form must be filed by every U.S. tax resident who has foreign financial accounts the aggregate value of which exceeds $10,000 at any time during the calendar year. The aggregate value should be calculated based on all foreign bank and financial accounts in which this U.S. tax resident has financial interest or over which he has signatory or other authority.

Failure to file an FBAR may result in the imposition of draconian FBAR penalties, including criminal penalties in grave cases of willful noncompliance.

FBAR PFIC Reporting: PFIC Definition

PFIC (Passive Foreign Investment Company) is one of the most complex tax requirements of the U.S. tax system. In addition to the potentially tremendously burdensome tax compliance required for PFICs, PFICs may result in the imposition of a much higher income tax with PFIC interest on the PFIC tax.

The basic definition of a PFIC is any foreign corporation in which: “(1) 75 percent or more of the gross income of such corporation for the taxable year is passive income, or (2) the average percentage of assets (as determined in accordance with subsection (e)) held by such corporation during the taxable year which produce passive income or which are held for the production of passive income is at least 50 percent.” IRC Section 1297(a). While many types of companies may unexpectedly be classified as PFICs by the IRS, foreign mutual funds seem to be the most common trap for the unwary U.S. taxpayers.

If a U.S. taxpayer has PFICs, he/she is required to file a separate Form 8621 “Information Return by a Shareholder of a Passive Foreign Investment Company or Qualified Electing Fund” for each PFIC.

FBAR PFIC Reporting: Three Potential FBAR Requirements

There are three most common situations when an FBAR should be filed for a PFIC, assuming the statutory aggregate threshold of $10,000 is satisfied. First, FBAR PFIC reporting is required if a PFIC is held in a financial account; in this case, FBAR PFIC reporting will occur for the account itself (which, in India especially, may correspond to the folio number of a PFIC in any case). For example, if a U.S. person has an Assurance Vie account in France that contains PFICs, he would have to report the Assurance Vie account on the FBAR, including the value of the PFICs.

Second, FBAR PFIC reporting is required if a PFIC shareholder has signature authority over foreign financial accounts owned by a PFIC. In this case, FBAR PFIC reporting will occur for these foreign financial accounts in Section IV of the FBAR.

Finally, the third most common situation where FBAR PFIC reporting is required is a scenario where a U.S. person owns more than 50% of a PFIC and this PFIC has foreign financial accounts. In such case, the U.S. person is assumed to have a financial interest in the foreign financial accounts of this PFIC and he needs to disclose these accounts on his FBAR.

FBAR PFIC Reporting: Filing Form 8621 does NOT Satisfy the FBAR Filing Requirement

It is important to emphasize that filing form 8621 for a PFIC does not relieve the filer from his FBAR obligations. Even if Form 8621 is filed, the filer must also file the FBAR.

Contact Sherayzen Law Office for Professional Help with FBAR PFIC Reporting

FBAR PFIC reporting can be extremely complex and it is very easy to make mistakes with respect to what needs to be disclosed and how. These mistakes, however, can be expensive to remedy and may result in imposition of various large penalties.

This is why, if you have PFICs that require FBAR and Form 8621 disclosure, you need to contact Sherayzen Law Office for professional help. Our team of experienced tax professionals will help you properly disclose your PFICs on your FBAR and report your PFIC income on your personal or business tax returns. If you have not complied with your FBAR PFIC reporting requirement in the past and wish to remedy this situation, Sherayzen Law Office will also help you with the voluntary disclosure of your FBARs and PFICs, including the preparation of all necessary tax forms and legal documents.

Contact Us Today to Schedule Your Confidential Consultation!

Remember to File Your 2015 FBARs | FBAR Tax Attorney

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On June 17, 2016, the IRS again reminded U.S. taxpayers with foreign accounts to file their 2015 FBARs by Thursday, June 30, 2016. U.S. taxpayers have to file 2015 FBARs if they had financial interest in or signatory authority (or other authority) over foreign accounts with values which, in the aggregate (i.e. all accounts added together), exceeded $10,000 at any time during the calendar year 2015. The taxpayers who satisfied the FBAR threshold, should e-file their 2015 FBARs through the BSA E-Filing System website.

It is important to note that the number of FBAR filings has grown exponentially. According to FinCEN data, on average, there has been a seventeen percent increase per year during the last five years. In fact, in 2015, FinCEN received a record high 1,163,229 of 2014 FBARs. We can reasonably expect that the number of 2015 FBARs will beat last year’s record.

The growth in the number of FBARs is mainly caused by two factors. First, the greater awareness of the FBAR requirement is due to a series of IRS legal victories against foreign banks and offshore jurisdictions, starting with 2008 UBS case through a complete destruction of the Swiss bank secrecy in the Swiss Bank Program and even more recent criminal conviction of two Caymanian banks.

Second and probably the most important reason is the implementation of the Foreign Account Tax Compliance Act (FATCA) which requires foreign financial institutions to report foreign accounts owned by U.S. persons. Additionally, FATCA created a new filing requirement, IRS Form 8938. Unlike the FBAR, Form 8938 has to be filed with U.S. individual tax returns (the implementation of Form 8938 for business returns still has not occurred). This new requirement created a much greater awareness of the FBAR among the accountants who generally do not file FBARs for their clients due to the fact that FBARs carry criminal penalties.

Both of these factors will continue to play a great role in 2016 when the 2015 FBARs have to filed. Additionally, by June 30, a much greater of foreign banks will have delivered FATCA letters, further promoting FBAR awareness among U.S. persons who have to file 2015 FBARs.

Contact Sherayzen Law Office for FBAR Help

If you have undisclosed foreign accounts for which delinquent FBARs have to be filed or you need help with determining what needs to be filed for 2015 FBAR, contact the experienced international tax law firm of Sherayzen Law Office. Our talented team of tax professionals, headed by a highly-experienced FBAR tax attorney, Mr. Eugene Sherayzen, has helped hundreds of U.S. taxpayers around the world and we can help you!

Contact Us Today to Schedule Your Confidential Consultation!