International Tax Lawyer Minneapolis

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Buona Sera, Seniorie Seniorie!

My name is Eugene Sherayzen and I am an International Tax Attorney. Before we delve into the subject matter of today’s presentation, I would like to give you some background information so that you have an idea of who I am and what it is that I do.

I’ve been an International Tax Attorney for about 11 years; I started practising law right after I graduated from Law school, passed the Bar and got my License all in one year, in 2005. I’ve devoted all these years between 2005 and to the present time to expanding my own Law Firm – Sherayzen Law Office, Ltd., which specializes in International Tax Compliance, in particular Offshore Voluntary Disclosures (this is the core area of my practice), but I also do Annual US Tax Compliance and International Tax Planning.

The nature of my practice is such that I have a very diverse Client base with Clients coming from over 60 Countries from every Continent permanently inhabited by human beings.

The majority of my Clients come from Europe both Western and Eastern, Southeast Asia, Canada and of course the United States. A significant number of my Clients come from Latin America and the Middle East and a small number of Clients come from Australia and some African countries like Nigeria.

There are several unique aspects of my firm that I would like to share with you today. First, we’re the only boutique law firm that offers such a wide range of International Tax Services; only very large Accounting and Law Firms do what I do on a regular basis. Second, we combine the Legal and the Accounting aspects of International Tax Practice in one firm.

This is unique; maybe firms like Ernst & Young do that but what it does is that it allows my firm to handle the entire case from the beginning to the end by itself without the necessity of retaining outside Accountants or Lawyers.

Finally, we are a truly International Law Firm because we offer services in three languages: English, Russian and Spanish… no Italian yet, though in a year or two I hope to add French and then we’ll see about the Italian.

International Tax Lawyers Madison | Importance of Avoiding International Tax Mistakes

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Let’s begin by answering a philosophical question. Why should you care? I mean after all, all of you here are Business Lawyers; So what if you make a Tax Mistake intentionally or unintentionally? After all you’re not Tax Lawyers.

Let me pose that question to you because all of you are here today for a reason; why do you care? Why did you come here? Why do you think it’s important for Business Lawyers to know how to avoid making International Tax Mistakes?

Any takers?

Audience member answer: “To keep our Clients out of jail.”

Okay, Good one!

Any other….?

Second audience member answer: “The Tax Consequences will affect the Bottom Line…. of your Business.”

Third audience member answer: “It will keep us out of jail too. That helps; don’t you think?”

Other comment: “So far, so good.” (Laughter)

Unknown audience member comment: “I think just to do anything confidently, you’ve got to know a lot about everything.”

Perfect; and I think all of you are right! If I were to summarize it, I would say that a Client will not appreciate if a Business Deal that you pulled together, no matter how perfect it is from the Business World Perspective, results in a tremendous increase in the Client’s Tax Liability, exposing the Client to huge IRS Civil Penalties and potentially Criminal Penalties because the Client could end up in jail for International Tax Noncompliance.

From the tax perspective, a badly structured Business Deal will boomerang back to you; first, in the form of losing a Client (because the Client will not stay with you after that), second, you might be facing a Legal Malpractice Lawsuit (which was mentioned here earlier) and the third thing is that potentially, it could be an Ethical Violation because you would be advising in a very Specialized Area in which you have no knowledge or experience. You might be endangering your Attorney License at that point.

Every Business Transaction Has Tax Consequences | International Tax Lawyers Indianapolis

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Now that we have established why we should care about making International Tax Mistakes, let’s discuss the five strategic traps which would expose you as Business Lawyers to making International Tax Mistakes.

I will follow along in this handout that you all have; hopefully everyone has it. Let’s start with the Business Purity Trap. A Business Purity Trap is an assumption that there is a purely Business Transaction that has no connection to Tax Law whatsoever and because there’s no connection to International Tax Law; obviously, there is no need to ask a Tax Advisor about this Transaction.

You cannot imagine how many times I see this. In one area where I see this most often is Business Formation, when Business Lawyers advise their Clients to form Business Entities and structure Business Transactions in a way that would entail information of different Business Entities throughout the world. Obviously, this gets their Clients into trouble because every Business Transaction has Tax Consequences.

Let me repeat that: Every Business Transaction has Tax Consequences.