Foreign Trust Tax Treatment in the United States: Historical Overview

Over the years, the US tax treatment of foreign trusts has undergone dramatic changes. It is important to study and understand this history in order to properly understand and interpret current US tax laws concerning foreign trust. In this essay, I will provide a broad overview of the history of foreign trust tax treatment in the United States since before 1962 until the present time.

Foreign Trust Tax Treatment Prior to 1962

Before 1962, the US tax laws treated in the same manner all foreign trusts, whether they had a US beneficiary or foreign one. A complex foreign trust established by a US grantor for the benefit of a US beneficiary was taxed similarly to the one established by a foreign granter for a US beneficiary. Moreover, since foreign-source income of a foreign trust was not included in the trust’s gross income for US income tax purposes, this trust would not have any DNI (distributable net income)!

Such treatment of foreign trusts led to a lot of abuse whereby large portions of income were never taxed in the United States. For example, prior to 1962, a foreign trust’s income would not be subject to US taxes in a situation where the trust was located in a country with low or no income taxes and the corpus consisted solely of foreign assets.

While in some situations US beneficiaries might have been taxed when the trust income was actually distributed (under the regular five-year throwback rule), careful tax planning could have prevented even such taxation of the beneficiaries in light of the fact that foreign-source income was excluded from DNI. Moreover, distributions of accumulated foreign trust income contained no undistributed net income (UNI) and were not subject to taxation under even the limited five-year throwback rule.

The Watershed Legislation in Foreign Trust Tax Treatment: the Revenue Act of 1962

The foreign trust tax treatment changed dramatically with the Revenue Act of 1962. The new legislation introduced two major changes to foreign trust tax treatment in the United States. First, it changed the calculation of DNI by requiring foreign trusts to add foreign-source income to it (unless such treatment was exempt by a treaty). Moreover, foreign trusts with US grantors now had to include capital gains in DNI.

Second, the Revenue Act of 1962 created the throwback rule on accumulation distributions from a foreign trust if the trust was created by a US person. Furthermore, important exceptions to throwback rule, such as exclusions for emergency distributions of accumulated income, were made unavailable to foreign trusts by the Act. Finally, the throwback rule became unlimited for foreign trusts while there was a five-year limitation on its application to domestic trusts.

Despite these profound changes in the foreign trust tax treatment, the Revenue Act of 1962 still failed to eliminate some important advantages of using foreign trusts to lower US tax liability. For example, the unlimited throwback rule did not seriously impact the foreign trust advantages in its ability for potentially unlimited tax deferral and tax-free income accumulation. Of course, this meant that the possibility of the rate of earnings of a foreign trust was likely to be much greater than that of US domestic trusts.

Furthermore, nothing was done to limit the ability of the US grantor and beneficiaries (and their families) to access undistributed funds of a foreign trust. For example, they could still receive these funds through loans, private annuities, like-kind exchanges and other similar “indirect” methods.

Finally, with respect to foreign trusts with US grantors, the foreign trusts were required to allocate capital gains to DNI. This meant that every distribution by a foreign trust contained a mixture of ordinary income and capital gains. US domestic trusts could not do that, because capital gains of a domestic trust could not be distributed until current and accumulated ordinary income was distributed.

Thus, perversely, the new foreign trust tax treatment afforded foreign trusts an important advantage in the form of its ability to distribute part of its capital gains to the beneficiaries more quickly than a domestic trust. This advantage became especially evident once the unlimited throwback rule was extended to domestic trusts in 1969.

Tightening of Screws in the Foreign Trust Tax Treatment: the Tax Reform Act of 1976

By 1976, these obvious advantages in the foreign trust tax treatment became unacceptable for the US Congress. Therefore, it acted in a major piece of US tax legislation known as the Tax Reform Act of 1976. While the Act was very broad, there were five key changes to the foreign trust tax treatment in the United States.

First, the new legislation re-classified foreign trusts that were created by US persons and had or could potentially have at least one US beneficiary as a grantor trust under IRC Section 679.

Second, the Act of 1976 required an automatic inclusion of capital gains of a foreign trust in the foreign trust’s DNI.

Third, it eliminated the loophole with respect to foreign trust distributions of income that accumulated prior to a beneficiary’s twenty-first birthday. Now, such distributions were taxed.

Fourth, with the obvious desire to attack the tax advantage in foreign trust tax treatment with respect to accumulated income, the Congress imposed a 6% simple interest charge on the tax imposed on a beneficiary of a foreign trust with respect to accumulations after December 31, 1976.

Finally, the last major change attacked the ability of US grantors to avoid US capital gain taxes by transferring appreciated assets into foreign trusts. The Act of 1976 imposed a 35% excise tax on the transfer of all appreciated assets to a foreign trust by a US grantor, unless the grantor elected to recognize the gain at the time of the transfer.

Changing the Foreign Trust Tax Treatment under IRC Section 672(f)

Another change in the foreign trust tax treatment came under the Revenue Reconciliation Act of 1990 with respect foreign grantor trusts that had a foreign grantor and a US beneficiary who had made gifts to the foreign grantor. This new law was summarized in IRC Section 672(f). Section 672(f) states that, in a situation where a foreign trust has a US beneficiary and should have been a grantor trust under the ordinary grantor trust rules found in IRC Sections 671 through 678 but for the fact that the grantor was a foreign person, this trust should be treated as owned by the trust’s US beneficiary to the extent that this beneficiary has made prior gifts to the foreign grantor.

There is still a small exception that a “gift shall not be taken into account to the extent such gift would be excluded from taxable gifts under section 2503(b).” 26 U.S.C. Section 672(f)(5)

1996 and 1997 Changes in the Foreign Trust Tax Treatment

The last major change in foreign trust tax treatment that I wish to mention here was introduced in the Small Business Job Protection Act of 1996 (as slightly modified by the Taxpayer Relief Act of 1997). The Act of 1996 introduced major revisions in the rules of foreign trust tax treatment, arguably on the scale of the Tax Reform Act of 1976.

Five major areas of foreign trust tax treatment were in focus. First, the definition of a foreign trust was clarified with a strong bias toward treating a trust as a foreign trust. Two new tests, the court test and the control test, were introduced (and clarified further in the Treasury regulations). These changes were codified in IRC Section 7701.

Second, the reporting requirements for foreign trusts (Forms 3520 and 3520-A) were introduced. This was a major change in the reporting burden for US taxpayers and foreign trusts with US beneficiaries.

Third, the penalties for failure to report transfers to a foreign trust were introduced.

Fourth, new rules were put in place to reduce the utility of foreign trusts by individuals who were planning to become US residents.

Finally, new restrictions were placed to reduce the utility of using foreign trusts by individuals who were planning to surrender their US residency or citizenship.

Contact Sherayzen Law Office for Tax Help With Foreign Trusts

Over the years, one can see profound changes in the foreign trust tax treatment; in this brief article, I only focused on some of the major changes in the foreign trust tax treatment, but there were other developments that took place (for example, FATCA compliance for foreign trusts).

These changes in foreign trust tax treatment generally indicate the trend toward stricter regulation of foreign trusts, increasing reporting burden on US taxpayers and foreign trusts, and the reduction in any type of an income tax advantage of foreign trusts. In fact, the foreign trust law has become so complex that one should not try to resolve these matters without the help of an experienced tax professional.

Despite these burdens, there is still a large number of foreign trusts with US grantors and US beneficiaries. The latter situation (i.e. US beneficiaries) often occurs when a foreign beneficiary becomes a US beneficiary through immigration. Oftentimes, these new US beneficiaries are not even aware of the existence of foreign trusts until significant US tax non-compliance occurs.

This is why it is so important to contact Sherayzen Law Office for professional help with respect to your foreign trusts as soon as possible. We have helped US beneficiaries, US grantors and foreign trusts around the world to do proper tax planning and comply with US reporting requirements (including Forms 3520, 3520-A and the voluntary disclosures associated with these forms). We can help You!

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Importance of Pre-Immigration Tax Planning

Pre-immigration tax planning is done by very few of the millions of immigrants who come to the United States. This is highly unfortunate because US tax laws are highly complex and it is very easy to get into trouble. The legal and emotional costs of bringing your tax affairs back into US tax compliance (after you violated any of these complex laws) are usually a lot higher than those of the pre-immigration tax planning. In this writing, I would like to discuss the concept and process of pre-immigration tax planning for persons who wish to immigrate and/or work in the United States.

The concept of pre-immigration tax planning is far more complex than what people generally believe. Most people simply focus on the actions required by local tax laws of their home country; very little attention is actually paid to the tax laws of the future host country – the United States. Perhaps, the only exception to this rule is avoidance of double-taxation; however, even this concept is approached narrowly to avoid only the taxation of US-source income by the home country.

Yet, the pre-immigration tax planning should focus on both, US tax laws and the laws of the home country. It is even safe to argue that a much larger effort should be going into US tax planning due to the much farther reach and the higher level of complexity of the US tax system; in fact, the capacity of US tax laws to invade one’s life is not something for which the new US immigrants are likely to be prepared. Furthermore, once a person emigrates to the United States, he will likely lose his tax residency in his home country.

Once the correct focus on US tax laws is adopted, the pre-immigration tax planning process should begin by securing a consultation with an international tax lawyer in the United States. Beware of using local tax lawyers who are not licensed in the United States to do your pre-immigration tax planning – having an idea of US tax laws is not the same as practicing US tax law. A separate article can be written on how to find and secure the right international tax lawyer, but, if you are reading this article, you already know that you should call Sherayzen Law Office for help with your pre-immigration tax planning!

During the consultation, your international tax lawyer should carefully go over your existing asset structure, their acquisition history, any built-up appreciation and other relevant matters. Then, he should classify the assets according to their likely US tax treatment and identify the problematic assets or assets which need further research. The lawyer should also discuss with you some of the most common US tax compliance requirements.

After the initial consultation, your US international tax lawyer will engage in preliminary pre-immigration tax planning, creating the first draft of your plan solely from US tax perspective.

Then, he will contact a tax professional in your home country (preferably a tax professional that you supply and who is familiar with your asset structure). If you have assets in multiple jurisdictions, the US lawyer should also contact tax attorneys in these jurisdictions in order to find out the tax consequences of his plan in these jurisdictions. He will then modify his plan based on these discussions to create the second draft of your pre-immigration tax plan.

The next step of your pre-immigration tax planning should be the discussion of the relevant details of the modified plan with your immigration lawyer in order to make sure that the plan does not interfere with your immigration goals. Once the immigration lawyer’s approval is secured, you can proceed with the implementation of the tax plan.

Obviously, this discussion of your pre-immigration tax planning is somewhat simplified in some aspects and overly structured in others. Not all of the steps need to be always followed, especially followed in the same order; a lot will depend on your asset structure and how complex or simple it is.

Finally, it is important to emphasize that pre-immigration tax planning applies not only to persons who wish to obtain US permanent residence, but also to persons who just wish to work (either as employees, contractors or business owners) in the United States, because these persons are likely to become US tax residents even if they never become US permanent residents.

Contact Sherayzen Law Office for Experienced Help With Your Pre-Immigration Tax Planning

If you are thinking of immigrating to or working in the United States, you need to contact a leading international tax law firm in this field, Sherayzen Law Office, for professional tax help. Our experienced legal team has helped foreign individuals and families around the world and we can help you!

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Hiding Assets and Income in Offshore Accounts Again Made the IRS “Dirty Dozen” List

On February 5, 2016, the IRS again stated that avoiding U.S. taxes by hiding money or assets in unreported offshore accounts remains on its annual list of tax scams known as the “Dirty Dozen” for the 2015 filing season.

The problem with offshore accounts is two-fold. On the one hand, there are numerous con-artists who use offshore accounts to lure taxpayers into scams and schemes. The second and a much larger problem for the IRS is the fact that many U.S. taxpayers used offshore account to hide assets and income from the IRS.

Fighting the strategy of using offshore accounts to hide assets and income has been one of the top priorities of the IRS since the early 2000s. The problem has been complicated by the fact that there are many legitimate reasons for having an offshore account – a fact that, unfortunately, has been largely ignored by journalists and the public opinion in the United States. Therefore, it is necessary for the IRS to approach the problem of offshore accounts carefully in order to avoid hurting innocent people.

Over the years, the IRS (with the help of Congress) has chosen five different and interrelated strategies to fight tax evasion through offshore accounts.

1. IRS Civil and Criminal Enforcement

IRS examinations, audits, subpoenas, and criminal enforcement play a central role in the IRS war against using offshore accounts to hide assets and income. The ability of the IRS to enforce U.S. tax laws is amazingly broad and the IRS will use it whenever it wishes.

Since 2009, the IRS conducted thousands of offshore-related civil audits that have produced tens of millions of dollars. The IRS has also pursued criminal charges leading to billions of dollars in criminal fines and restitutions.

Hence, brute force still looms large in fighting tax evasion through offshore accounts and creates enormous (and fully justified) fear in the hearts of many U.S. taxpayers. This fear is also central to the IRS ability to use the other four strategies listed below.

2. Extensive Reporting Requirement for Owners of Offshore Accounts

As owners of offshore accounts have already noticed, the number of reporting requirements with respect to offshore accounts has risen dramatically. In addition to FBAR (which has existed since the 1970s), FATCA introduced Form 8938 in 2011. Furthermore, Form 8621 and Schedule B to Form 1040 have been modified to require additional reporting with respect to offshore accounts. Other forms also indirectly require reporting of foreign accounts (through reporting of ownership or a beneficial interest in a foreign entity or a foreign trust).

By forcing U.S .taxpayers to do extensive reporting with respect to their offshore accounts, the IRS has achieved two goals at the same time. First, it has collected an enormous amount of information with respect to U.S. offshore accounts and their owners. This information can be used in a later investigation to track fund and identify patterns of behavior. In a short while, due to the implementation of FATCA in many jurisdictions around the world, this information will also be used to compare the banks’ information with the information provided by the taxpayers on their information returns.

Second, the enormous fines associated with offshore accounts reporting can create huge tax liabilities for noncompliant taxpayers. This provides the IRS with a financial incentive to pursue these taxpayers. These potentially disastrous noncompliance fines also serve to deter many taxpayers from engaging in risky tax evasion schemes.

Of course, one of the biggest problems associated with these reporting requirements is that the majority of persons, including tax accountants, never heard of them until they were already in trouble. When the IRS pressure started to rise, it was already too late for a lot of U.S. taxpayers to do simply current compliance and they had to pay fines to the IRS. It is important to emphasize that the process is by no means over – on the contrary, as the complexity of U.S. tax compliance continues to rise, a lot of taxpayers (and their accountants) still do not know about a lot of these requirements.

3. Voluntary Disclosures

In order to alleviate the reporting noncompliance nightmares for U.S .taxpayers, the IRS created a number of voluntary disclosure programs. The early programs were not very successful; however, after the IRS stunning victory in the 2008 UBS case, the 2009 Offshore Voluntary Disclosure Initiative (OVDI) turned out to be a huge success. The 2011 OVDP, 2012 OVDP and 2014 OVDP with 2014 Streamlined Compliance Procedures followed in quick succession and with even bigger success. Since 2009, more than 54,000 OVDP disclosures took place and the IRS has collected more than $8 billion; this is not taking into account the huge surge in Streamlined disclosures since 2014.

The information that has been collected through OVDP is used to identify noncompliant individuals and entire schemes to evade U.S. taxes through offshore accounts. The IRS then uses this information to pursue taxpayers with undeclared offshore accounts, as well as the banks and bankers suspected of helping clients hide their assets overseas using offshore accounts. The IRS works closely with the Department of Justice (DOJ) to prosecute these tax evasion cases.

4. Swiss Bank Program

In addition to the voluntary disclosure program for individuals, the IRS also created a voluntary disclosure program for Swiss banks. Such voluntary disclosure program is, of course, an unprecedented event – never in history did one country force another country’s entire bank system to do a voluntary disclosure on the territory of that other country.

While the debate over this breach of Swiss sovereignty (although, technically, the Swiss government agreed to the Swiss Bank Program) is interesting, for the purposes of this article, it is important to note that Swiss Bank program was a huge step forward in attacking the usage of offshore accounts to hide assets and income.

By the end of February of 2016, about 80 Swiss banks went through Category 2 voluntary disclosure and paid penalties to the U.S. government. They also turned over enormous amount of information regarding their U.S. accountholders and the various schemes that Swiss bankers developed to hide assets and funds from the IRS. In essence, the Swiss bankers turned over to the IRS substantially all of the blueprints for tax evasion that they had created.


The final major strategy for fighting the practice of using offshore accounts to hide assets and income from the IRS is the famous Foreign Account Tax Compliance Act or FATCA. Ever since FATCA entered into force, it has changed the global landscape of international tax compliance. One of the most salient features of FATCA is the fact that it forces foreign banks to report to the IRS all of the offshore accounts that they can identify as owned by U.S. persons.

This groundbreaking piece of legislation has had an enormous impact on the ability of the IRS to identify noncompliance by U.S. persons, because foreign banks now act as its agents and voluntarily disclose U.S. persons and their offshore accounts.

Contact Sherayzen Law Office for Help With Your Offshore Accounts

If you have undisclosed offshore accounts, you should contact Sherayzen Law Office as soon as possible. We have helped hundreds of U.S. taxpayers to bring their U.S. tax affairs in order while saving millions of dollars in potential penalty reductions. We furthermore help to reduce your income tax liability as a result of your voluntary disclosure and post-voluntary disclosure tax planning.

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Higher OVDP Penalty Risk for US Taxpayers With Foreign Accounts

December of 2015 was one of the most successful months for the DOJ’s Swiss Bank Program as nearly a record number of banks signed non-prosecution agreements. This success for the DOJ means that more and more of non-compliant US taxpayers with foreign accounts are likely to deal with Higher OVDP Penalty with respect to their undisclosed foreign accounts.

DOJ’s Swiss Bank Program

The Program for Non-Prosecution Agreements or Non-Target Letters for Swiss Banks (Program) was announced by the US Department of Justice on August 29, 2013. The Program was intended to achieve multiple goals, but there are four of them that are most important to the understanding of the Higher OVDP Penalty and the Program.

First, this was an “offer that one cannot refuse” for the Swiss banks– the Program was intended to “allow” (or force) Swiss banks to bring themselves into compliance with US tax laws. In exchange, the Swiss banks received a non-prosecution agreement that promised them protection from US legal enforcement actions.

Second, the Program was intended to obtain as much information as possible about non-compliant US taxpayers with foreign accounts.

The third important goal was to create an atmosphere of global enforcement that would make US voluntary disclosure the most rational choice for non-compliant US taxpayers with foreign accounts given the risk of IRS discovery of their undisclosed foreign accounts.

Fourth, the Program was intended to pave the way for easier acceptance of FATCA throughout the world by demonstrating what could potentially happen in any country that decides to resist the implementation of FATCA.

It must be stated that the Swiss Bank Program has been a spectacular success for the DOJ and the IRS. Both, the banks and non-compliant US taxpayers with foreign accounts flocked to the voluntary disclosure programs. Moreover, today, FATCA is the new global standard of international tax enforcement.

2014 OVDP

The current 2014 IRS Offshore Voluntary Disclosure Program is a modification of 2012 OVDP which, in turn, was the continuation of a series of prior IRS offshore voluntary disclosure programs (particularly 2011 OVDI). The 2014 OVDP is designed to help non-compliant US taxpayers with foreign accounts to bring their tax affairs into compliance with US tax laws.

2014 OVDP has a two-tier penalty system. The 50% penalty rate applies to US taxpayers with foreign accounts in the banks on the special IRS list. The 27.5% penalty rate applies to everyone else.

Influence of the Program on the OVDP

The Swiss Bank Program has a direct impact on the IRS Offshore Voluntary Disclosure Program because every Swiss Bank that signs a Non-Prosecution Agreement under the Program is automatically added to the 50% penalty list of foreign banks.

Thus, as more and more Swiss Banks reach an agreement with the DOJ under the Program, the list of 50% penalty banks keeps expanding and so does the list of US taxpayers with foreign accounts who may be subject to this higher penalty rate.

What Should Non-Compliant US Taxpayers With Foreign Accounts Do?

The growing risk of higher OVDP penalty means that non-compliant US taxpayers with foreign accounts should explore their voluntary disclosure options as soon as possible by contacting an experienced international tax lawyer.

It is a mistake to assume that 50% penalty list will grow only as a result of the Swiss Bank Program. Even today, the list already contains banks which are located outside of the United States (such as HSBC India and Israeli Bank Leumi). This means that any bank in almost any part of the world may tomorrow be on the 50% penalty list and US taxpayers with foreign accounts in this bank would be forced to pay a much higher penalty.

Contact Sherayzen Law Office for Professional Tax Help With The Voluntary Disclosure of Your Foreign Accounts

The growing risk of higher OVDP penalty means that you should contact the experienced international tax team of Sherayzen Law Office. International tax attorney and Founder of Sherayzen Law Office, Mr. Eugene Sherayzen, will personally analyze your case, estimate your IRS penalty exposure, determine your offshore voluntary disclosure options, and implement your customized voluntary disclosure plan to resolve your US tax problems.

US Income Tax Obligations of Green Card Holders: General Overview

There is a common misconception among Green Card Holders (a common name for US permanent residents) that their US income tax obligations are limited in nature in comparison to US citizens. In this article, I seek to dispel this erroneous myth and provide some general outlines of the US income tax obligations of Green Card Holders.

US Income Tax Obligations of Green Card Holders: Worldwide Income Reporting

I receive a lot of phone calls from Green Card holders who believe that their US income tax reporting obligations are limited only to US-source income (sourcing of income, by the way, is also a very complex subject and I often see egregious mistakes committed even by experienced accountants).

This is not correct. In fact, US permanent residents and US citizens are both considered to be “tax residents of the United States.” US tax residents are required to report their worldwide income on US tax returns and pay US income taxes on foreign-source income (and, obviously, US-source income).

Thus, if you have a Green Card and you have foreign assets (such as foreign bank and financial accounts, foreign businesses, foreign trusts, et cetera), you must report the income from such foreign assets on your US tax returns.

Be careful! You must remember that all foreign income must be reported in US dollars and according to US tax laws. Leaving aside the issue of currency conversion (which is a topic for another article), the reporting of foreign income under US tax laws may be extremely challenging because foreign tax laws may treat this income in a different manner. Let me emphasize this point – the treatment of income under foreign local tax rules may not actually be the same as the treatment of the same income under US tax rules.

For example, Assurance Vie accounts in France may be completely tax-exempt if certain conditions are met. However, the annual income from these accounts must be reported on US tax returns.

Moreover, to make matters worse, these accounts may contain PFIC (Passive Foreign Investment Company) investments which are treated in a very complex and generally unfavorable manner under US tax laws. The calculation of US tax liability in this case may be extremely complex (especially since the French banks are not required to keep the kind of information that is necessary to properly calculation PFIC tax and interest).

US Income Tax Obligations of Green Card Holders: Reporting of Foreign Bank and Financial Accounts

As US tax residents, the Green Card holders are also required to disclose their ownership of certain foreign bank and financial accounts to the IRS. Many US permanent residents are shocked to learn about these requirements and the draconian penalties associated with failure to file the required information reports.

The top two bank and financial account reporting requirements are FinCEN Form 114 (known as “FBAR” – the Report of Foreign Bank and Financial Accounts) and Form 8938 (which was born out of FATCA). Other forms, such as Form 8621, may apply.

It is beyond the scope of this article to discuss these requirements in detail. However, it is impossible to overstate their importance, especially the FBAR, due to potentially astronomical non-compliance penalties (including criminal penalties). You can find more information about these requirements at

US Income Tax Obligations of Green Card Holders: Reporting of Foreign Business Ownership

Many US permanent residents are surprised to find out that they may be required to provide detailed reports about their foreign businesses – corporations, partnerships and disregarded entities. Indeed, Green Card holders may be subject to burdensome and expensive US reporting requirements on Forms 5471, 8865, 926, 8938, et cetera. These forms may require Green Card holders to provide foreign financial statements translated under US accounting standards, including US GAAP (Generally Accepted Accounting Practices).

Again, you can find more information about these requirement at

US Income Tax Obligations of Green Card Holders: Reporting of Foreign Trusts

Another complex trap for Green Card Holders is reporting of an ownership or a beneficiary interest in a foreign trust (generally, on Form 3520). This complicated topic is beyond the scope of this article, but you can find more information about these requirements at

US Income Tax Obligations of Green Card Holders: Other Reporting Requirements

There are numerous other US income tax obligations of Green Card Holders that may apply. Moreover, US has multiple income tax treaties with various countries which may modify your particular tax situation. In order to fully determine your US tax obligations as a Green Card holder, it is best to consult with an experienced international tax attorney.

Contact Sherayzen Law Office for Help With Your US Income Tax Obligations

Sherayzen Law Office is a specialized international tax law firm which is highly experienced in helping US Permanent Residents with their US income tax obligations and reporting requirements. One of the unique features of our firm is that our tax team provides both legal and accounting services to our clients throughout the world.

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