International Tax Lawyers Los Angeles | Linguistic Uniformity Trap

As I was preparing for this presentation today, it occurred to me that there is a sixth trap which is not really common but it does exist. It’s not really even limited to Business Lawyers; it really exists throughout the profession but because it’s such an important trap, I decided to share it with you.

I call it the Linguistic Uniformity Trap. It’s basically a belief that same tax terms have the same meaning, especially when we’re talking about English-speaking countries.

The term ‘Capital Gain’ would mean the same thing in the United States and in the UK; that’s a belief. Sometimes it’s true and sometimes it’s not.

If you would like to learn more, you should contact me directly at [email protected] or call me at (952) 500-8159.

IRS Statute of Limitations | US International Tax Lawyer Zurich

“Hello and welcome to Sherayzen Law Office video blog. My name is Eugene Sherayzen; I’m an international tax attorney and owner of Sherayzen Law Office, Ltd.

Today, I would like to discuss with you an interesting and very important concept in US Tax Law:  Statute of Limitations. The Statute of Limitations basically means that there is a certain period of time when the IRS can go back and open up a certain tax form or an entire tax return for examination. The general Statute of Limitation under US Tax Law for a normal 1040 is three years; however, there are a number of important exceptions. One of the exceptions for example is when you do not disclose more than 25% of your income on your US Tax Returns. In this case, the Statute of Limitations extends to six years.

Now if you also fail to file an international information return with your US Tax Return, then you may be facing a situation where the Statute of Limitations never starts to run. In other words, the IRS can go back in time and open up that form forever, potentially forever. I have had in my personal practice situations where during an audit and IRS would go back 18, 20 years to open up a tax return for examination and imposition of penalties.

US Tax Law is filled with concepts like this, complex concepts, and it’s important to understand them before you make your decision on how to proceed with respect to the reporting of your foreign assets and foreign income.

If you would like to know more about US Tax Law or you would like to have a consultation, with respect to a specific international tax issue, you should contact me directly at: (952) 500-8159 or email me at: [email protected].

Thank you for watching until the next time.

FATCA Tax Lawyer Karlovy Vary

Hello and welcome to Sherayzen Law Office Video Blog. My name is Eugene Sherayzen; I’m an international tax attorney and owner of Sherayzen Law Office Ltd.

And today we are continuing our series of blogs from Czech Republic and we are in Karlovy Vary; a very famous resort where high-net worth individuals come to rest, to cure their diseases, to drink mineral water, but some of these individuals are also US Tax Residents. And unfortunately one of the problems US Tax Residents face is compliance with very extensive and intrusive US Tax Reporting Requirements.

One of these requirements is FATCA. Now FATCA is a huge piece of legislation that was passed in 2010, that revolutionized the entire legal landscape around the world with respect to information exchange and tax compliance.

There are three parts of FATCA which have relevance for ordinary individual and corporate tax, US Taxpayers. One of them is the requirement for foreign financial institutions to report foreign accounts owned by US Persons; the second one is a tax withholding requirement of 30% on the gross transactions if the foreign financial institution is not tax compliant, same by the way, applies by the way to US Taxpayers with foreign accounts which have not been disclosed to the IRS or for which the US Taxpayers refused to give the permission to the foreign institutions to disclose. And finally the third requirement is form 8938. Now form 8938 is part of the internal revenue code now and it should be filed with your US Tax Return. Failure to file form 8938 may have grave consequences, including the extension of the Statute of Limitations, the imposition of civil and even criminal penalties.

If you would like to learn more about your US Tax Reporting Requirements, you should contact me directly at [email protected] or call me at (952) 500-8159. Thank you for watching; until the next time.