“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.
http://sherayzenlaw.com/wp-content/uploads/2018/01/sherlawltd_logo.png00Managerhttp://sherayzenlaw.com/wp-content/uploads/2018/01/sherlawltd_logo.pngManager2019-12-10 00:48:412021-12-28 18:59:46IRS 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.
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.
http://sherayzenlaw.com/wp-content/uploads/2018/01/sherlawltd_logo.png00Managerhttp://sherayzenlaw.com/wp-content/uploads/2018/01/sherlawltd_logo.pngManager2019-09-26 16:32:482021-12-28 20:28:10FATCA 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 vlog in Zurich Switzerland and right now we’re walking towards one of the most prestigious, one of the most expensive, and one of the most bank-filled if you will, streets in the world: Bahnhofstrasse.
Bahnhofstrasse is known in the banking world for being the headquarters of some of the largest banks in the world. It is also known for being one of the top places for international assets management and international tax planning.
And now we have reached one of the most exciting and important places in US voluntary disclosure history, UBS Bank. UBS is important because it was precisely the IRS victory over the UBS that opened the door to the IRS intrusion into Switzerland and ultimately took down, completely destroyed, annihilated the concept of bank secrecy in Switzerland with respect to US Taxpayers.
It was also the beginning of a series of highly successful US voluntary disclosure programs. It was precisely the US victory in 2008 over UBS that lead to the creation of the (now discontinued) 2009 Offshore Voluntary Disclosure Program or OVDP.
http://sherayzenlaw.com/wp-content/uploads/2018/01/sherlawltd_logo.png00Managerhttp://sherayzenlaw.com/wp-content/uploads/2018/01/sherlawltd_logo.pngManager2019-09-26 15:05:582024-01-05 21:33:03The End of Swiss Bank Secrecy
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IRS Statute of Limitations | US International Tax Lawyer Zurich
/in International tax attorney & lawyer Video /by Manager“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
/in International tax attorney & lawyer Video /by ManagerHello 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.
The End of Swiss Bank Secrecy
/in International tax attorney & lawyer Video /by ManagerHello, 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 vlog in Zurich Switzerland and right now we’re walking towards one of the most prestigious, one of the most expensive, and one of the most bank-filled if you will, streets in the world: Bahnhofstrasse.
Bahnhofstrasse is known in the banking world for being the headquarters of some of the largest banks in the world. It is also known for being one of the top places for international assets management and international tax planning.
And now we have reached one of the most exciting and important places in US voluntary disclosure history, UBS Bank. UBS is important because it was precisely the IRS victory over the UBS that opened the door to the IRS intrusion into Switzerland and ultimately took down, completely destroyed, annihilated the concept of bank secrecy in Switzerland with respect to US Taxpayers.
It was also the beginning of a series of highly successful US voluntary disclosure programs. It was precisely the US victory in 2008 over UBS that lead to the creation of the (now discontinued) 2009 Offshore Voluntary Disclosure Program or OVDP.