Posts

Offshore Voluntary Disclosure: Client Records | International Tax Lawyer

/in , , /by

One of the first things a client must get in order to pursue an offshore voluntary disclosure are all of the client records from his former accountant. Sometimes, however, the clients are having difficulty obtaining their documents from their accountants. In this article, I would like to briefly describe an accountant’s obligations with respect to the return of client records to their clients.

Return of Client Records: General Obligation to Return All Client Documents

Subsection 10.28(a) of Circular 230 requires an accountant to promptly return, upon a client’s request, any and all of the records of the client that are necessary for the client to comply with his federal tax obligations. Hence, a failure of an accountant to return all clients records to his or her client is a violation of the accountant’s IRS obligations.

Return of Client Records: Documents Included

31 CFR §10.28(b) defines the documents that an accountant must return to his client:

  1. All documents or written or electronic materials provided to the practitioner, or obtained by the practitioner in the course of the practitioner’s representation of the client, that preexisted the retention of the practitioner by the client;
  2. All materials that were prepared by the client or a third party (not including an employee or agent of the practitioner) at any time and provided to the practitioner with respect to the subject matter of the representation; and
  3. Any return, claim for refund, schedule, affidavit, appraisal or any other document prepared by the practitioner, or his or her employee or agent, that was presented to the client with respect to a prior representation if such document is necessary for the taxpayer to comply with his or her current federal tax obligations.

Return of Client Records: Documents Excluded

31 CFR §10.28(b) also expressly excludes from the definition of client records “any return, claim for refund, schedule, affidavit, appraisal or any other document prepared by the practitioner or the practitioner’s firm, employees or agents if the practitioner is withholding such document pending the client’s performance of its contractual obligation to pay fees with respect to such document”.

Hence, in most cases, it is important for a client to pay his outstanding fees to the accountant in order to make sure that he has all relevant documents. Later, if he wishes, the client may file a lawsuit against the accountant for negligence (if there are legal grounds for such a lawsuit) to recover the fees paid.

Contact Sherayzen Law Office to Help With the Voluntary Disclosure of Your Prior US Tax Noncompliance

If you have not disclosed your foreign income and/or foreign assets to the IRS in violation of your US tax obligations, you should contact Sherayzen Law Office as soon as possible for professional help.  We have helped hundreds of US taxpayers to bring their tax affairs into compliance with US tax laws, including through a voluntary disclosure such as SDOP (Streamlined Domestic Offshore Procedures), SFOP (Streamlined Foreign Offshore Procedures), DFSP (Delinquent FBAR Submission Procedures), DIIRSP (Delinquent International Information Return Submission Procedures), IRS VDP (IRS Voluntary Disclosure Practice) and Reasonable Cause disclosures. We can help you!

Contact Us Today to Schedule Your Confidential Consultation!

Galveston FBAR Attorney | International Tax Lawyer Texas

/in , /by

If you are a resident of Galveston, Texas, and you have unreported foreign bank and financial accounts, you may be looking for Galveston FBAR Attorney. In your search, consider Mr. Eugene Sherayzen of Sherayzen Law Office, Ltd. (“Sherayzen Law Office”). Let’s understand why this is the case.

Galveston FBAR Attorney: International Tax Lawyer

First of all, it is very important to understand that, by looking for Galveston FBAR attorney, in reality, you are searching for an international tax lawyer who specializes in FBAR compliance.

The reason for this conclusion is the fact that FBAR enforcement belongs to a very special field of US tax law – US international tax law. FBAR is an information return concerning foreign assets, which necessarily involves US international tax compliance concerning foreign assets/foreign income. Moreover, ever since the FBAR enforcement was turned over to the IRS in 2001, the term FBAR attorney applies almost exclusively to tax attorneys.

Hence, when you look for an FBAR attorney, you are looking for an international tax attorney with a specialty in FBAR compliance.

Galveston FBAR Attorney: 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 Galveston, Texas. On the contrary, consider international tax attorneys who reside in other states and help Galveston residents with their FBAR compliance.

Sherayzen Law Office is an international tax law firm that specializes in US international tax compliance, including FBARs. While our office is in Minneapolis, Minnesota, we help taxpayers who reside throughout the United States, including Galveston, Texas.

Galveston FBAR Attorney: Broad Scope of Compliance and Offshore Voluntary Disclosures

When retaining Galveston FBAR attorney, consider the fact that such an attorney’s work is not limited only to the preparation and filing of FBARs. Rather, the attorney should be able to deliver a variety of tax services and freely operate with experience and knowledge in all relevant areas of US international tax law, including the various offshore voluntary disclosure options concerning delinquent FBARs.

Moreover, as part of an offshore voluntary disclosure, an FBAR Attorney often needs to amend US tax returns, properly prepare foreign financial statements according to US GAAP, correctly calculate PFICs, and complete an innumerable number of other tasks.

Mr. Sherayzen and his team of motivated experienced tax professionals of Sherayzen Law Office have helped hundreds of US taxpayers worldwide to bring their tax affairs into full compliance with US tax laws. This work included the preparation and filing of offshore voluntary disclosures concerning delinquent FBARs. Sherayzen Law Office offers help with all kinds of offshore voluntary disclosure options, including: SDOP (Streamlined Domestic Offshore Procedures), SFOP (Streamlined Foreign Offshore Procedures), DFSP (Delinquent FBAR Submission Procedures), DIIRSP (Delinquent International Information Return Submission Procedures), IRS VDP (IRS Voluntary Disclosure Practice) and Reasonable Cause disclosures.

Thus, if you are looking for a Galveston FBAR Attorney, contact Mr. Sherayzen as soon as possible to schedule Your Confidential Consultation!