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San Antonio FBAR Tax Attorney | International Tax Lawyer Texas

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If you reside in San Antonio, Texas, and have unreported foreign bank and financial accounts, you may be looking for a San Antonio FBAR Tax Attorney.  Sherayzen Law Office, Ltd. is a leader in FBAR compliance, including offshore voluntary disclosures concerning delinquent FBARs, and you should consider us in your search. Let’s understand why this is the case.

San Antonio FBAR Tax Attorney: International Tax Lawyer

First of all, it is very important to understand that, by looking for San Antonio FBAR Tax 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.

San Antonio FBAR Tax Attorney: Broad Scope of Compliance and Offshore Voluntary Disclosures

When retaining a San Antonio FBAR Tax Attorney, consider the fact that such an attorney’s work is not limited 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.

San Antonio FBAR Tax 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 San Antonio, Texas. On the contrary, consider international tax attorneys who reside in other states and help San Antonio residents with their FBAR compliance.

Contact Sherayzen Law Office for Professional FBAR Help

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 San Antonio, Texas. We can help with annual FBAR compliance, FBAR compliance in combination with other international tax forms as well as offshore voluntary disclosures.

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

San Antonio FBAR Attorney | International Tax Lawyers Texas

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If you have foreign financial accounts and reside in San Antonio (Texas), you would be looking for a San Antonio FBAR Attorney in Texas. In your search, you could consider out-of-state attorneys such as Mr. Eugene Sherayzen of Sherayzen Law Office, Ltd. (“Sherayzen Law Office”). Let’s explore in more detail why this is the case.

San Antonio FBAR Attorney: International Tax Attorney

First of all, it is very important to understand that, by looking for a San Antonio FBAR attorney, in reality, you are looking for an international tax attorney whose specialty includes FBAR compliance.

Ever since the FBAR enforcement was turned over to the IRS (in 2001), the term FBAR attorney applies exclusively to tax attorneys.

Moreover, FBAR enforcement belongs to a very special field of US tax law – US international tax law. The reason for this is simple: FBAR is an information return concerning foreign assets and the tax compliance concerning foreign assets and foreign income belongs to US international tax law. Hence, when you look for an FBAR attorney, you are looking for an international tax attorney with a specialty in FBAR compliance.

San Antonio FBAR Attorney: Out-Of-State International Tax Attorney

It is further important to note that, since you are looking for an attorney who specializes in US international tax law (i.e. a federal area of law), you do not need to limit yourself to lawyers who reside in San Antonio, Texas. On the contrary, you should consider international tax attorneys who reside in other states and help San Antonio 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 San Antonio, Texas.

San Antonio FBAR Attorney: Broad Scope of Compliance

When retaining a San Antonio FBAR Attorney, you should consider the fact that such an attorney’s work is not limited only to the preparation and filing of FBARs. Rather, the attorney needs to be able to deliver a variety of 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.

Contact Sherayzen Law Office If You Need A San Antonio FBAR Attorney

Sherayzen Law Office has 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 an attorney to help with your FBAR compliance, contact Sherayzen Law Office to secure Your Confidential Consultation!

Last Swiss Bank Program Category 2 Resolution

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On January 27, 2016, the US Department of Justice (DOJ) declared the last Swiss Bank Program Category 2 Resolution. The Swiss Bank Program was proclaimed on August 29, 2013, and constituted an unprecedented triumph of US economic might over the most formidable bank secrecy bulwark (though, already a greatly weakened one since the 2008 UBS case) which Switzerland had been for hundreds of years.

Under the Swiss Bank Program, the Swiss banks were forced to turn over a large amount of information regarding foreign accounts held by US persons, cooperate with US information requests, and, in case of category 2 banks, pay a fine. In return, the Swiss banks were provided a guarantee against US criminal prosecution in the form of non-prosecution agreements.

The Swiss Bank Program was successful, though not every eligible Swiss bank actually chose to participate in the Program. The most profitable part of the Program consisted of the Category 2 banks, which had to pay fines as a condition of their participation in the Swiss Bank Program.

The first resolution with a Category 2 bank occurred on March 30, 2015. On January 27, 2016, the last Swiss Bank Program Category 2 resolution took place after reaching a Non-Prosecution Agreement with HSZH Verwaltungs AG (HSZH).

In total, the DOJ signed Non-Prosecution Agreements with about 80 banks and collected more than $1.36 billion in Swiss Bank Penalties, including $49 million from the last Swiss Bank Program Category 2 resolution. While this amount pales in comparison with the originally-projected amounts (due to penalty mitigation), the enormous impact the Program has had on the worldwide US tax compliance and convincing foreign governments to accept FATCA render this Program an important success for the US government.

The final Swiss Bank Program Category 2 resolution marked the end of the Category 2 part of the Swiss Bank Program, but an important question remains – will we see the re-appearance of the Swiss Bank Program with Category 2 banks in another country? While the implementation of FATCA reduces the probability of a chance of another program similar to Swiss Bank Program, one cannot fully discount this possibility. It is possible that the IRS will identify another important center (such as the Cayman Islands, Hong Kong, Isle of Mann, Singapore, et cetera) of US tax non-compliance based on the information collected in the Swiss Bank Program and attack this center.

On the other hand, one can also see the appearance of a global “Swiss Bank Program” which banks of any country can enter in order to prevent US criminal prosecution.

Whatever form the future voluntary disclosure program for foreign banks will take, one can be certain that the last Swiss Bank Program Category 2 Resolution with HSZH was not the last IRS enforcement effort with respect to foreign banks.