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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!

IRS Wins Against Wells Fargo’s Tax Shelter Scheme | Int’l Tax Lawyers MN

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On May 25, 2017, the IRS sealed another victory against the infamous abusive tax shelter known as STARS (Structured Trust Advantaged Repackaged Securities).

The actual victory occurred on November 17, 2016, when a jury in Minnesota found Wells Fargo guilty of engaging in abusive tax shelter and determined that Wells Fargo was not entitled to a about $350 million of foreign tax credits. On May 25, 2017, however, the IRS expanded that victory when the Minnesota federal district court found Wells Fargo liable for a 20 percent negligence penalty.

Wells Fargo’s Tax Shelter Scheme can be traced to Barclays Bank PLC (“Barclays”). Barclays marketed the STARS transaction to American banks, including Wells Fargo. STARS was designed to exploit differences between the tax laws in the United States and in the United Kingdom.

Wells Fargo’s Tax Shelter Scheme is not the first one to be rejected by courts. In fact, at this point, three other cases have rejected the STARS tax shelters similar to Wells Fargo’s Tax Shelter Scheme. These case are: Bank of New York, BB&T Bank and Santander Bank purchased. Santander Holdings USA, Inc. v. United States, 844 F.3d 15 (1st Cir. 2016), pet. for cert. filed, March 20, 2017 (No. 16 1130); Bank of N.Y. Mellon Corp. v. Comm’r, 801 F.3d 104 (2d Cir. 2015), cert. denied, 136 S. Ct. 1377 (2016); Salem Fin., Inc. v. United States, 786 F.3d 932 (Fed. Cir. 2015), cert. denied, 136 S. Ct. 1366 (2016).

The recent victory by the IRS against Wells Fargo’s Tax Shelter Scheme is an important reminder of the salience of the business purpose doctrine in US international tax law. Sherayzen Law Office has previously written on the doctrine and emphasized how crucial it is to distinguish legitimate tax planning from engaging in abusive tax shelters.

Sherayzen Law Office advocates an approach that emphasizes legitimate tax planning that allows US taxpayers to utilize the advantages offered by US tax laws without engaging in abusive tax schemes, like STARS.