This seminar is organized by the International Business Law Section and co-sponsored by the Trust Law Section of the Minnesota State Bar Association. My name is Eugene Sherayzen and I’ll be your speaker today.
First, a few words about myself; then we’ll get to the subject matter of today’s presentation.
I’m an International Tax Attorney and owner of Sherayzen Law Office, Ltd., a law firm that specializes in International Tax Compliance, in particular, Offshore Voluntary Disclosures, International Tax Planning and Annual US International Tax Compliance.
Every year, I’ve filed hundreds of income and information tax returns as part of my Annual Compliance and International Tax Practice.
As of the end of 2018, I’ve dealt with assets in over 70 countries and I have conducted Tax Compliance with respect to pretty much every major asset class and every type of major Business Tax Transaction. So, we’re talking about disclosure of Foreign Bank and Financial Accounts, Foreign Business Ownership, Foreign Corporations, Foreign Partnerships, Foreign Trusts, Foreign Gifts and Foreign Inheritance.
Here is the list of most countries where the clients of Sherayzen Law Office, Ltd. have assets: Australia, Canada, Cook Islands, New Zealand, Western Europe (Austria, Belgium, France, Germany, Iceland, Ireland, Italy, Liechtenstein, Luxembourg, Monaco, Portugal, Spain, Sweden, Switzerland and United Kingdom), Eastern Europe (Belarus, Croatia, Cyprus, Czech Republic, Hungary, Lithuania, Poland, Russian Federation and Ukraine), Asia (Bangladesh, China, Hong Kong, India, Japan, Kazakhstan, Philippines, Singapore, South Korea, Thailand, Uzbekistan and Vietnam), Middle East (Dubai, Egypt, Iran, Iraq, Israel, Jordan, Kuwait, Lebanon, Oman and Turkey), Africa (Cote D’Ivore, Ethiopia, Morocco, Nigeria and Sudan), the Caribbean region (Bahamas, Barbados, Jamaica, Saint Kitts and Nevis, Trinidad & Tobago and Cayman Islands), and Latin America (Argentina, Belize, Brazil, Chile, Colombia, Costa Rica, El Salvador, Nicaragua, Mexico, Panama and Paraguay).
Here is the list of states of the United States in which you can retain Sherayzen Law Office’s international tax services: Alabama, Alaska, Arizona, Arkansas, California, Colorado, Connecticut, Delaware, Florida, Georgia, Hawaii, Idaho, Illinois, Indiana, Iowa, Kansas, Kentucky, Louisiana, Maine, Maryland, Massachusetts, Michigan, Minnesota, Mississippi, Missouri, Montana, Nebraska, Nevada, New Hampshire, New Jersey, New Mexico, New York, North Carolina, North Dakota, Ohio, Oklahoma, Oregon, Pennsylvania, Rhode Island, South Carolina, South Dakota, Tennessee, Texas, Utah, Vermont, Virginia, Washington, West Virginia, Wisconsin, Wyoming.
http://sherayzenlaw.com/wp-content/uploads/2018/01/sherlawltd_logo.png00adminhttp://sherayzenlaw.com/wp-content/uploads/2018/01/sherlawltd_logo.pngadmin2020-05-13 16:58:192024-08-23 18:46:12International Tax Law Firm | Sherayzen Law Office, Ltd.
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, we are continuing our vlog from Zurich, Switzerland. We are standing in front of the Julius Baer or Baer Bank here in downtown Zurich. Julius Baer is a Multinational Private Bank which was investigated by the IRS and entered into the anti-prosecution deferral agreement with the US Department of Justice in 2016; it paid over $500 million dollars in Penalties and agreed to disclose all of its US Clients to the Department of Justice.
A bank which does not comply with US Tax Reporting Requirements, which assists US Taxpayers in hiding foreign income or foreign assets is likely to draw the wrath of the US Department of Justice and may face criminal prosecution from the US Government.
This is why it is important for Foreign Financial Institutions to stay in Compliance with FATCA and CRS. If you are a banker who is interested in developing a FATCA Compliance Program for your bank, contact me directly at (952) 500-8159 or email me at [email protected].
Hello, and welcome to Sherayzen Law Office video blog. My name is Eugene Sherayzen and I’m an international tax attorney and owner of Sherayzen Law Office, Ltd.
Today, I would like to discuss with you one of the most interesting problems that almost every taxpayer faces when he does a Voluntary Disclosure: the issue of current Tax Compliance. Let me explain what I mean by this.
Let’s suppose that you discovered (that) you have not filed your form 8938 or perhaps FBAR; let’s say you haven’t done that for a number of years. At this point you’re not able to obtain all the documentation necessary to complete the amended tax forms or to complete the necessary tax forms in order to file your Voluntary Disclosure. So, in essence what you’re facing is an issue of whether to disclose your foreign accounts and potential past non-compliance at this point or to wait and then disclose everything when you file your Voluntary Disclosure.
The temptation is to file the tax documents as they are without disclosing anything with respect to your foreign accounts and foreign income. However, this temptation must be resisted at all costs. Let me explain why.
If you file your tax forms without the disclosure of foreign accounts and foreign income and you know that you must disclose these foreign accounts and income, then you’re doing it with knowledge; in other words, the IRS may allege that you are doing this willfully. If you are doing this willfully, then it’s going to be very hard for you to participate, later on in the Streamlined Voluntary Disclosure.
The concern that many taxpayers have with disclosing foreign accounts that even if they don’t have all the documentation is that they are afraid that the IRS will find out about it and will commence an investigation and thereby prevent any possibility of participating in a Voluntary Disclosure Program. This, of course, is a valid concern. The issue really is ‘how much time will it take to complete the Voluntary Disclosure documentation.’ If it takes three years, then yes, this is a huge concern. If it takes less, then it’s less of a concern. If it takes just two or three months, maybe half a year, you should have enough time to complete your Voluntary Disclosure.
Let’s suppose the worst-case scenario: you file your current year compliance correctly or as accurately as you could have filed it and let’s suppose that the IRS finds out about it before you could do the Voluntary Disclosure, then at the very least, you will have an argument at that point that you were trying to disclose this and this will support your non-willfulness later on during the IRS Audit.
On the other hand, if you don’t disclose anything and the IRS finds out about your prior tax non-compliance, then at that point, what you will be facing is a potentially willful situation; in other words willful penalties and maybe even Criminal Penalties.
If you would like to discuss your Voluntary Disclosure more, contact me as soon as possible; you can call me at (952) 500-8159 or you can email me at [email protected].
Thank you for watching, until the next time.
http://sherayzenlaw.com/wp-content/uploads/2018/01/sherlawltd_logo.png00adminhttp://sherayzenlaw.com/wp-content/uploads/2018/01/sherlawltd_logo.pngadmin2020-05-07 14:09:502024-08-23 18:51:36Streamlined Disclosure vs. Current Tax Compliance | SDOP Lawyer
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International Tax Law Firm | Sherayzen Law Office, Ltd.
/in International tax attorney & lawyer Video /by adminThis seminar is organized by the International Business Law Section and co-sponsored by the Trust Law Section of the Minnesota State Bar Association. My name is Eugene Sherayzen and I’ll be your speaker today.
First, a few words about myself; then we’ll get to the subject matter of today’s presentation.
I’m an International Tax Attorney and owner of Sherayzen Law Office, Ltd., a law firm that specializes in International Tax Compliance, in particular, Offshore Voluntary Disclosures, International Tax Planning and Annual US International Tax Compliance.
Over the course of my practice, I’ve conducted literally hundreds of Offshore Voluntary Disclosures of every type, including the IRS Offshore Voluntary Disclosure Program, the last version which closed on September 28, 2018, Streamlined Domestic Offshore Procedures, Streamlined Foreign Offshore Procedures, Delinquent FBAR Submission Procedures, Delinquent Information Return Submissions and Reasonable Cause Disclosures.
Every year, I’ve filed hundreds of income and information tax returns as part of my Annual Compliance and International Tax Practice.
As of the end of 2018, I’ve dealt with assets in over 70 countries and I have conducted Tax Compliance with respect to pretty much every major asset class and every type of major Business Tax Transaction. So, we’re talking about disclosure of Foreign Bank and Financial Accounts, Foreign Business Ownership, Foreign Corporations, Foreign Partnerships, Foreign Trusts, Foreign Gifts and Foreign Inheritance.
Here is the list of most countries where the clients of Sherayzen Law Office, Ltd. have assets: Australia, Canada, Cook Islands, New Zealand, Western Europe (Austria, Belgium, France, Germany, Iceland, Ireland, Italy, Liechtenstein, Luxembourg, Monaco, Portugal, Spain, Sweden, Switzerland and United Kingdom), Eastern Europe (Belarus, Croatia, Cyprus, Czech Republic, Hungary, Lithuania, Poland, Russian Federation and Ukraine), Asia (Bangladesh, China, Hong Kong, India, Japan, Kazakhstan, Philippines, Singapore, South Korea, Thailand, Uzbekistan and Vietnam), Middle East (Dubai, Egypt, Iran, Iraq, Israel, Jordan, Kuwait, Lebanon, Oman and Turkey), Africa (Cote D’Ivore, Ethiopia, Morocco, Nigeria and Sudan), the Caribbean region (Bahamas, Barbados, Jamaica, Saint Kitts and Nevis, Trinidad & Tobago and Cayman Islands), and Latin America (Argentina, Belize, Brazil, Chile, Colombia, Costa Rica, El Salvador, Nicaragua, Mexico, Panama and Paraguay).
Here is the list of states of the United States in which you can retain Sherayzen Law Office’s international tax services: Alabama, Alaska, Arizona, Arkansas, California, Colorado, Connecticut, Delaware, Florida, Georgia, Hawaii, Idaho, Illinois, Indiana, Iowa, Kansas, Kentucky, Louisiana, Maine, Maryland, Massachusetts, Michigan, Minnesota, Mississippi, Missouri, Montana, Nebraska, Nevada, New Hampshire, New Jersey, New Mexico, New York, North Carolina, North Dakota, Ohio, Oklahoma, Oregon, Pennsylvania, Rhode Island, South Carolina, South Dakota, Tennessee, Texas, Utah, Vermont, Virginia, Washington, West Virginia, Wisconsin, Wyoming.
Julius Baer & Importance of FATCA Compliance | Zurich FATCA Tax Lawyer
/in International tax attorney & lawyer Video /by adminHello, 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, we are continuing our vlog from Zurich, Switzerland. We are standing in front of the Julius Baer or Baer Bank here in downtown Zurich. Julius Baer is a Multinational Private Bank which was investigated by the IRS and entered into the anti-prosecution deferral agreement with the US Department of Justice in 2016; it paid over $500 million dollars in Penalties and agreed to disclose all of its US Clients to the Department of Justice.
A bank which does not comply with US Tax Reporting Requirements, which assists US Taxpayers in hiding foreign income or foreign assets is likely to draw the wrath of the US Department of Justice and may face criminal prosecution from the US Government.
This is why it is important for Foreign Financial Institutions to stay in Compliance with FATCA and CRS. If you are a banker who is interested in developing a FATCA Compliance Program for your bank, contact me directly at (952) 500-8159 or email me at [email protected].
Thank you for watching, until the next time.
Streamlined Disclosure vs. Current Tax Compliance | SDOP Lawyer
/in International tax attorney & lawyer Video /by adminHello, and welcome to Sherayzen Law Office video blog. My name is Eugene Sherayzen and I’m an international tax attorney and owner of Sherayzen Law Office, Ltd.
Today, I would like to discuss with you one of the most interesting problems that almost every taxpayer faces when he does a Voluntary Disclosure: the issue of current Tax Compliance. Let me explain what I mean by this.
Let’s suppose that you discovered (that) you have not filed your form 8938 or perhaps FBAR; let’s say you haven’t done that for a number of years. At this point you’re not able to obtain all the documentation necessary to complete the amended tax forms or to complete the necessary tax forms in order to file your Voluntary Disclosure. So, in essence what you’re facing is an issue of whether to disclose your foreign accounts and potential past non-compliance at this point or to wait and then disclose everything when you file your Voluntary Disclosure.
The temptation is to file the tax documents as they are without disclosing anything with respect to your foreign accounts and foreign income. However, this temptation must be resisted at all costs. Let me explain why.
If you file your tax forms without the disclosure of foreign accounts and foreign income and you know that you must disclose these foreign accounts and income, then you’re doing it with knowledge; in other words, the IRS may allege that you are doing this willfully. If you are doing this willfully, then it’s going to be very hard for you to participate, later on in the Streamlined Voluntary Disclosure.
The concern that many taxpayers have with disclosing foreign accounts that even if they don’t have all the documentation is that they are afraid that the IRS will find out about it and will commence an investigation and thereby prevent any possibility of participating in a Voluntary Disclosure Program. This, of course, is a valid concern. The issue really is ‘how much time will it take to complete the Voluntary Disclosure documentation.’ If it takes three years, then yes, this is a huge concern. If it takes less, then it’s less of a concern. If it takes just two or three months, maybe half a year, you should have enough time to complete your Voluntary Disclosure.
Let’s suppose the worst-case scenario: you file your current year compliance correctly or as accurately as you could have filed it and let’s suppose that the IRS finds out about it before you could do the Voluntary Disclosure, then at the very least, you will have an argument at that point that you were trying to disclose this and this will support your non-willfulness later on during the IRS Audit.
On the other hand, if you don’t disclose anything and the IRS finds out about your prior tax non-compliance, then at that point, what you will be facing is a potentially willful situation; in other words willful penalties and maybe even Criminal Penalties.
If you would like to discuss your Voluntary Disclosure more, contact me as soon as possible; you can call me at (952) 500-8159 or you can email me at [email protected].
Thank you for watching, until the next time.