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Dallas Foreign Inheritance Lawyer | International Tax Attorney Texas

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Retaining a Dallas foreign inheritance lawyer to deal with the IRS is very likely to be necessary if you reside in Dallas, 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 Dallas foreign inheritance lawyer.

Dallas 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 Dallas 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.

Dallas 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.

Dallas 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 Dallas 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 Dallas and all over the world.  We also have a highly valuable experience of combining income tax planning with offshore voluntary disclosures.

Dallas Foreign Inheritance Lawyer: Offshore Voluntary Disclosures

When retaining a Dallas 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 Dallas 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 Dallas, 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.

Dallas 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 Dallas, Texas. On the contrary, consider international tax attorneys who reside in other states and help Dallas 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 Dallas area. Hence, Dallas 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 Dallas Foreign Inheritance Lawyer, contact Mr. Sherayzen now to schedule Your Confidential Consultation!

Minneapolis Foreign Inheritance Lawyer | International Tax Attorney Minnesota

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Retaining a Minneapolis foreign inheritance lawyer to deal with the IRS is very likely to be necessary if you reside in Minneapolis, Minnesota 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 Minneapolis foreign inheritance lawyer.

Minneapolis 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 Minneapolis 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.

Minneapolis 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.

Minneapolis 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 Minneapolis 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 Minneapolis and all over the world.  We also have a highly valuable experience of combining income tax planning with offshore voluntary disclosures.

Minneapolis Foreign Inheritance Lawyer: Offshore Voluntary Disclosures

When retaining a Minneapolis 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 Minneapolis 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 Minneapolis, 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.

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 are based in Minneapolis, Minnesota, with an extensive local Minnesota clientele. We have helped numerous clients in Minnesota with their foreign inheritance. We can help you!

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

Foreign Inheritance Definition | International Tax Lawyer & Attorney

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Foreign inheritance definition is a topic of crucial importance for both US income and US estate tax compliance, because domestic inheritance and foreign inheritance have vastly different income tax results and reporting requirements. Hence, the topic of foreign inheritance definition directly concerns millions of Americans who reside overseas and tens of millions of Americans who have relatives outside of the United States. In this article, I will explore the foreign inheritance definition and warn against the common tax traps associated with it.

Foreign Inheritance Definition: Confusion Among Taxpayers

There is an enormous confusion right now among many US taxpayers with respect to US tax compliance requirements concerning a foreign inheritance. Some taxpayers firmly believe that a foreign inheritance is never subject to US taxation, some adopt an exactly opposite position while the rest simply do not know what to think.

It appears that the notion that foreign inheritance is non-taxable was acquired by reading various articles on the internet that state exactly this point. The people who believe that foreign inheritance is taxable also draw their conclusion from the internet – the difference arises from the fact that they read different articles. Finally, the third category of taxpayers read both kinds of articles and they simply do not know who to believe.

What is going on? Why is it that the articles on the internet seem to draw mutually-exclusive conclusions? Is one category of articles correct while the other one is one hundred percent wrong?

The answer to these questions lies in identifying the purpose for which an internet article was written, because the source of confusion lies in the foreign inheritance definition. It turns out that there are two definitions with separate applicable US tax compliance requirements!

Foreign Inheritance Definition for Income Tax Purposes

The first foreign inheritance definition exists for income tax purposes only. Under this rule, foreign inheritance is an inheritance received from a decedent who is a non-resident alien.

In this context, “non-resident alien” is defined by the IRS income tax rules. In other words, a non-resident alien is a person who does not fall into any of the tax residency categories. He cannot be a US citizen or US permanent resident; he did not stay long enough to satisfy the Substantial Presence Test; and he never declared himself a US tax resident (for example, by filing a joint US tax return with his US spouse).

Foreign Inheritance Definition for Estate Tax Purposes

A different definition of foreign inheritance applies under the US estate tax rules. Here, a foreign inheritance is defined as an inheritance received from a decedent who is a nonresident noncitizen. A noncitizen is a nonresident if he is domiciled outside of the United States. The term “domicile” here means acquiring a place to live without a present intention of later leaving. There are various factors used to determine a person’s domicile.

It is important to understand that, due to these two different definitions of a foreign inheritance, it is possible that a person could be a tax resident for income tax purposes and a nonresident noncitizen for estate tax purposes. Vice-versa may also be true.

Foreign Inheritance Definition and Tax Consequences

Now that we understand that there is a separate foreign inheritance definition for each tax regime (income and estate), we can clarify the confusion that prevails on the internet and among US taxpayers.

Generally, if the decedent was a non-resident alien, then neither his estate nor his US heirs would be subject to income taxes at the time of inheritance. I wish to emphasize here that this rule applies only “at the time of inheritance”, not before or after the foreign inheritance takes place. Exceptions may be possible with respect to foreign trusts.

On the other hand, if an inheritance was received from a taxpayer who is domiciled in the United States, then it will be subject to US estate tax rules irrespective of the country where the inherited assets are located. Of course, estate tax treaties may provide a certain amount of relief against double-taxation in this case.

If an inheritance was received from a nonresident noncitizen, then all foreign assets, except those considered as “US situs assets”, will avoid US estate taxation. The US situs assets above the exclusion of $60,000, however, may still be taxed in the United States.

Contact Sherayzen Law Office for Professional Tax Help With Your Foreign Inheritance

All of the rules that I have stated here are general, and your international tax attorney needs to apply them to your specific fact pattern in order to determine whether an inheritance fits a foreign inheritance definition for either estate or income tax purposes or both.

Furthermore, one should remember that “non-taxable” does not mean “non-reportable”. There are various income tax information reporting requirements that may apply to you even if your foreign inheritance was not taxable. Additionally, income tax recognition may be required in certain situations with respect to your foreign inheritance, especially before and after the you are deemed to have inherited your foreign assets.

Under these circumstances, the help of Sherayzen Law Office is of critical importance if you wish to stay in US tax compliance and avoid high IRS tax penalties. We are an international tax law firm highly experienced in US tax compliance concerning a foreign inheritance. We have successfully helped US taxpayers all over the globe with their foreign inheritance issues, and We can help You!

Contact Us Today to Schedule Your Confidential Consultation About Your Foreign Inheritance!

Sherayzen Law Office, Ltd. Conducts Foreign Inheritance Seminar | News

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On January 17, 2019, Mr. Eugene Sherayzen, an international tax attorney and owner of Sherayzen Law Office, Ltd., conducted a foreign inheritance seminar for the International Business Law and Probate and Trust Law Sections of the Minnesota State Bar Association. The title of the seminar was “Foreign Inheritance – the Pandora’s Box of U.S. International Tax Reporting Requirements.”

Foreign Inheritance Seminar

Foreign Inheritance Seminar, MSBA, 01/17/2019

This foreign inheritance seminar was well-attended; there were close to 50 attendees. The majority of the attendees were business and estate planning lawyers; there were also a few immigration lawyers.

Mr. Sherayzen defined the main goal of the seminar as broadening the awareness of the U.S. international tax implications of receiving a foreign inheritance. He first focused on the definition of the concept of “foreign inheritance”, exposing the complexity behind this term. Mr. Sherayzen further explained how this term is defined for income tax versus estate tax purposes. He concluded this first part of the seminar by going over a set of hypothetical situations and explaining the U.S. tax consequences the foreign inheritance definition would have in each of them.

During the second part of the seminar, Mr. Sherayzen explained the reporting requirements associated with foreign inheritance. He also explained the difference between the taxability of a foreign inheritance and the reporting of a foreign inheritance. A foreign inheritance may still be required to be reported to the IRS even if it is not taxable.

Mr. Sherayzen devoted the third part of the foreign inheritance seminar to pre-inheritance transfers of assets by a foreign decedent. He explained how an international tax attorney has to analyze each of these transfers in the context of three main strategic issues: classification, income recognition and information reporting. The attorney then focused on the example that embodied all three of these issues – the usufruct.

During the final part of the seminar, Mr. Sherayzen focused on the post-inheritance U.S. tax compliance issues. The attorney described, in a broad manner, the income tax and information tax reporting requirements associated with various classes of assets.  Additionally, Mr. Sherayzen separately discussed the concept of a foreign trust, stated its main reporting requirements and introduced the complications concerning the foreign trust income tax recognition.

Contact Sherayzen Law Office for Professional Tax Help With Your Foreign Inheritance Reporting to the IRS

If you are about to receive or already received a foreign inheritance, contact Sherayzen Law Office for professional help. We are a team of tax professionals highly experienced in U.S. international tax reporting of a foreign inheritance as well as offshore voluntary disclosures which involve inherited foreign assets. We have helped hundreds of U.S. taxpayers with their IRS foreign inheritance issues; and We can help You!

Contact Us Today to Schedule Your Confidential Consultation!