Before we delve into the subject matter of today’s discussion, I’d like to introduce myself so that you know a little bit about who I am and what it is I do.
I know that about half of you already know but the other half does not. As I’ve just said in my crude French a minute ago, I’m an international Tax Lawyer and owner of Sherayzen Law Office, Ltd., a law firm that specializes in International Tax Compliance, in particular Offshore Voluntary Disclosures and this is by far my biggest area of law or sub-area: Annual US Tax Compliance, IRS Audits and Appeals and International Tax Planning.
I’ve dealt with clients from over 60 countries with assets around the world including Francophone countries like France, Belgium, and Switzerland – the French part of Switzerland and even some French speaking African countries.
Unfortunately, I only offer my services in three languages at this point: English, Russian and Spanish but maybe in a couple of years I’ll do it in French as well.
http://sherayzenlaw.com/wp-content/uploads/2018/01/sherlawltd_logo.png00adminhttp://sherayzenlaw.com/wp-content/uploads/2018/01/sherlawltd_logo.pngadmin2020-04-30 22:13:222024-01-04 22:31:49International Tax Lawyer Twin Cities | Introduction to Law Firm
The Tax Owner is really a Holder of Economic Interest, not necessarily the Legal owner of the actual entity.
Let me clarify that with an example. Let’s say this is a Taxpayer; this is the LLC and he owns 100% of that LLC. The LLC owns 50% of the Limited Partnership. The Taxpayer owns 50% of the Limited Partnership.
How many entities do we have for US Tax Purposes? Does anyone want to take a gander? The Taxpayer is not an entity. There’s a maximum of two available.
Anyone else want to guess? None. There are no entities for US Tax Purposes here.
This is Disregarded because it’s 100% owned. Because there’s one, a single Holder of Economic Interest, the Taxpayer from both sides is basically that the Taxpayer’s being treated as 100% Disregarded Entity.
You cannot have a one Partner; there’s always got to be at least two Partners. So, the Taxpayer owns the assets of the LP and the LLC directly for US Tax Purposes. That’s what I mean by the Holder of Economic Interest.
http://sherayzenlaw.com/wp-content/uploads/2018/01/sherlawltd_logo.png00adminhttp://sherayzenlaw.com/wp-content/uploads/2018/01/sherlawltd_logo.pngadmin2020-04-30 21:55:222021-12-28 16:42:55US Business Tax Lawyer | Tax Definition of Business Owner
US Owners: I listed out for you what US Owner means.
It’s US Citizens, US Tax Residents, meaning Permanent Residents and a person who has satisfied the US Presence Test, Non-residents who declare themselves as Tax Residents for the purposes of filing a joint tax return are also considered to be US Owners.
Residents of Puerto Rico and all other US Possessions are also considered to be US Owners.
http://sherayzenlaw.com/wp-content/uploads/2018/01/sherlawltd_logo.png00adminhttp://sherayzenlaw.com/wp-content/uploads/2018/01/sherlawltd_logo.pngadmin2020-04-30 21:26:432022-03-10 23:16:52International Tax Lawyers Duluth | Definition of US Owners
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International Tax Lawyer Twin Cities | Introduction to Law Firm
/in International tax attorney & lawyer Video /by adminBefore we delve into the subject matter of today’s discussion, I’d like to introduce myself so that you know a little bit about who I am and what it is I do.
I know that about half of you already know but the other half does not. As I’ve just said in my crude French a minute ago, I’m an international Tax Lawyer and owner of Sherayzen Law Office, Ltd., a law firm that specializes in International Tax Compliance, in particular Offshore Voluntary Disclosures and this is by far my biggest area of law or sub-area: Annual US Tax Compliance, IRS Audits and Appeals and International Tax Planning.
I’ve dealt with clients from over 60 countries with assets around the world including Francophone countries like France, Belgium, and Switzerland – the French part of Switzerland and even some French speaking African countries.
Unfortunately, I only offer my services in three languages at this point: English, Russian and Spanish but maybe in a couple of years I’ll do it in French as well.
US Business Tax Lawyer | Tax Definition of Business Owner
/in International tax attorney & lawyer Video /by adminThe Tax Owner is really a Holder of Economic Interest, not necessarily the Legal owner of the actual entity.
Let me clarify that with an example. Let’s say this is a Taxpayer; this is the LLC and he owns 100% of that LLC. The LLC owns 50% of the Limited Partnership. The Taxpayer owns 50% of the Limited Partnership.
How many entities do we have for US Tax Purposes? Does anyone want to take a gander? The Taxpayer is not an entity. There’s a maximum of two available.
Anyone else want to guess? None. There are no entities for US Tax Purposes here.
This is Disregarded because it’s 100% owned. Because there’s one, a single Holder of Economic Interest, the Taxpayer from both sides is basically that the Taxpayer’s being treated as 100% Disregarded Entity.
You cannot have a one Partner; there’s always got to be at least two Partners. So, the Taxpayer owns the assets of the LP and the LLC directly for US Tax Purposes. That’s what I mean by the Holder of Economic Interest.
International Tax Lawyers Duluth | Definition of US Owners
/in International tax attorney & lawyer Video /by adminUS Owners: I listed out for you what US Owner means.
It’s US Citizens, US Tax Residents, meaning Permanent Residents and a person who has satisfied the US Presence Test, Non-residents who declare themselves as Tax Residents for the purposes of filing a joint tax return are also considered to be US Owners.
Residents of Puerto Rico and all other US Possessions are also considered to be US Owners.