Hello and welcome to Sherayzen Video Blog. My name is Eugene Sherayzen and I’m an international tax attorney and owner of Sherayzen Law Office, Ltd.
Today, I’m continuing a series of blogs from San Antonio, Texas and this series of blogs is devoted to IRS audits, how they happen, when they happen and what way is the best way in dealing with them.
In the previous blog, I discussed how one should behave with respect to IRS agents. In this blog I’d like to discuss a slightly different issue and step away a little bit directly from litigation and talk about San Antonio’s specific issues. In particular, I want to talk about FBAR compliance for San Antonians: FBAR, the report of foreign bank and financial accounts is one of the most important information returns that one has to file with respect to his foreign bank and financial accounts, specifically with respect to his financial interest in or signatory authority over foreign bank and financial accounts.
In this case, we’re talking about foreign accounts which are located outside of the United States of course. When we are talking about FBAR compliance, with respect to San Antonians, you have to understand what countries are most likely to be involved in FBAR compliance. What I’m talking about is specifically with respect to San Antonians. From my experience here, most of the San Antonians, who have to file FBARs, have assets in Mexico, Spain and/or Germany. In reality, you sometimes get people from all over the world; there are people from Sri Lanka, for example. There are also people from England, people from Italy, Colombia and so basically while Spain, Germany and Mexico are the major countries involved in FBAR compliance, these are not the only countries. It is very important to be in compliance with your FBAR requirements; I cannot stress this enough. We’re talking about humongous penalties in case of FBAR noncompliance; penalties that may extend to actual jail time depending on the circumstances of the (your) case.
If you would like to learn more about FBAR compliance and you are a resident of San Antonio, call me 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.png00adminhttp://sherayzenlaw.com/wp-content/uploads/2018/01/sherlawltd_logo.pngadmin2024-09-05 22:27:072024-09-06 17:04:26FBAR Compliance in San Antonio | FBAR International Tax Lawyer San Antonio Texas
Hello and welcome to Sherayzen Video Blog. My name is Eugene Sherayzen and I’m an international tax attorney and owner of Sherayzen Law Office, Ltd.
Today, I’m continuing my series of blogs from San Antonio, Texas. In the previous blog, I discussed the importance of full disclosure of facts to your international tax attorney after you receive your IRS letter and after you contact your attorney or retain your attorney with respect to this audit.
In this blog, I would like to discuss the importance of proper behavior with respect to IRS agents. There is an absolutely erroneous opinion which is being propagated by unsavory characters (let’s put it this way) that the best strategy in an IRS audit is to be aggressive against the IRS and deny everything, do not sign anything, basically no matter what the facts of your circumstances are, be as hostile to the IRS as possible.
This is absolutely wrong; I cannot tell you how wrong this is. The IRS has tremendous powers to find out about your case to enforce the law against you and to basically punish you for being noncooperative during their investigation and in most cases, but I would say in all cases but as an attorney, I cannot say ‘in all cases’, in the vast majority of cases, let’s put it this way. In the vast majority of cases, the best strategy is the one that is adapted to the facts of the case. In the vast majority of these cases, the strategy is one of cooperation, honesty, disclosure but strong defense of your position. Ethical defense. Logical defense. Defense that does not offend the IRS personally but the one that states your position in the logical, legally, justified way.
You want to have a cordial relationship with the IRS agent. You want the IRS agent to understand that you are not a criminal; that you are not a person who lies. You want them to trust you with respect to what you tell them. They want to trust your ability to deliver on what you promised to deliver.
The strategy that is based on lying to the IRS, hiding from the IRS, swearing at the IRS, fighting them at every point whether it is necessary or not necessary is completely wrong. This is not to say that your defense should not be strong, of course, you must always strongly defend your position as long as it is a justifiable position. There are certain points that sometimes are better to be conceded and explained. The defense of your case will be based on a strategy, not on hostility to the IRS, because hostility to the IRS is usually a counterproductive way to conduct and IRS audit. As I’ve said: cordial, polite but a strong defense; you will have your position, you will have your facts and this position and these facts should form the basis of your defense against the IRS.
If you would like to learn more about an IRS audit, and if you’d like to secure my help with respect to your defense in an IRS audit, you can call me at (952) 500-8159 or you can email me at [email protected]
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.pngadmin2024-09-05 22:07:092024-09-05 22:18:09Strategy and Behavior During IRS Audit | International Tax Audit Attorney San Antonio Texas
Hello and welcome to Sherayzen Video Blog. My name is Eugene Sherayzen and I’m an international tax attorney and owner of Sherayzen Law Office, Ltd.
Today, I’m continuing my series of blogs from San Antonio, Texas. In this series of blogs, I discuss issues related to IRS audits. In the previous video, I mentioned that the Inflation Reduction Act provided a humongous sum of money to the IRS to hire new IRS agents to conduct field audits. In fact the IRS said that it has plans to increase its staff by 40,000 people; this is an enormous amount of people. This means that the capacity of the IRS to audit US taxpayers is going to increase manifold.
In the previous video, I also mentioned that it is important for taxpayers to start preparing for an IRS audit before it actually happens. What does it mean to be preparing for an IRS audit? First of all, the preparation for an IRS audit must begin before a tax return is ever submitted, meaning that all tax positions that you are taking should be well documented and even better, if they’re not only documented but also disclosed to the IRS. That is do not take a position, with respect to a tax issue and not disclose it to the IRS. If the IRS later disagrees with you, they may think that you actually did it intentionally or tried to hide something. In this case, in order to avoid this issue, it is better to basically disclose it in a small statement saying, for example, “based on the IRC section internal revenue code, we’re taking the position that this and this and this must happen”. That’s it; a small statement, you don’t have to provide a huge analysis, just disclose it to the IRS either as an IRS audit at that point, the IRS cannot claim willfulness in your approach as long as your position is reasonable of course, based to a degree on certain facts.
Preparation for an IRS audit must happen already when the tax return is being prepared and submitted to the IRS; that’s the first stage.
The second stage is to get supporting documentation, organize it and that means not only getting the bank statements or statements from your broker but it also means getting the statements from third parties in support for your position – that’s the second stage of preparation.
The final stage of the preparation for an IRS audit involves saving all of that information; that is very important. Many people think that once they have prepared everything and put everything together, that it is enough. In reality, there may be years before an IRS audit happens and if you do not have this information, you will not be able to prove to the IRS that you once had it. Please make sure that you safeguard the information related to a possible audit.
In the next video, I will discuss how an IRS audit begins.
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.pngadmin2024-09-05 20:11:572024-09-20 19:04:31IRS Audit Preparation With Annual Tax Compliance | IRS International Tax Audit Lawyer San Antonio
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FBAR Compliance in San Antonio | FBAR International Tax Lawyer San Antonio Texas
/in International tax attorney & lawyer Video /by adminHello and welcome to Sherayzen Video Blog. My name is Eugene Sherayzen and I’m an international tax attorney and owner of Sherayzen Law Office, Ltd.
Today, I’m continuing a series of blogs from San Antonio, Texas and this series of blogs is devoted to IRS audits, how they happen, when they happen and what way is the best way in dealing with them.
In the previous blog, I discussed how one should behave with respect to IRS agents. In this blog I’d like to discuss a slightly different issue and step away a little bit directly from litigation and talk about San Antonio’s specific issues. In particular, I want to talk about FBAR compliance for San Antonians: FBAR, the report of foreign bank and financial accounts is one of the most important information returns that one has to file with respect to his foreign bank and financial accounts, specifically with respect to his financial interest in or signatory authority over foreign bank and financial accounts.
In this case, we’re talking about foreign accounts which are located outside of the United States of course. When we are talking about FBAR compliance, with respect to San Antonians, you have to understand what countries are most likely to be involved in FBAR compliance. What I’m talking about is specifically with respect to San Antonians. From my experience here, most of the San Antonians, who have to file FBARs, have assets in Mexico, Spain and/or Germany. In reality, you sometimes get people from all over the world; there are people from Sri Lanka, for example. There are also people from England, people from Italy, Colombia and so basically while Spain, Germany and Mexico are the major countries involved in FBAR compliance, these are not the only countries. It is very important to be in compliance with your FBAR requirements; I cannot stress this enough. We’re talking about humongous penalties in case of FBAR noncompliance; penalties that may extend to actual jail time depending on the circumstances of the (your) case.
If you would like to learn more about FBAR compliance and you are a resident of San Antonio, call me at (952) 500-8159 or email me at [email protected]
Thank you for watching, until the next time.
Strategy and Behavior During IRS Audit | International Tax Audit Attorney San Antonio Texas
/in International tax attorney & lawyer Video /by adminHello and welcome to Sherayzen Video Blog. My name is Eugene Sherayzen and I’m an international tax attorney and owner of Sherayzen Law Office, Ltd.
Today, I’m continuing my series of blogs from San Antonio, Texas. In the previous blog, I discussed the importance of full disclosure of facts to your international tax attorney after you receive your IRS letter and after you contact your attorney or retain your attorney with respect to this audit.
In this blog, I would like to discuss the importance of proper behavior with respect to IRS agents. There is an absolutely erroneous opinion which is being propagated by unsavory characters (let’s put it this way) that the best strategy in an IRS audit is to be aggressive against the IRS and deny everything, do not sign anything, basically no matter what the facts of your circumstances are, be as hostile to the IRS as possible.
This is absolutely wrong; I cannot tell you how wrong this is. The IRS has tremendous powers to find out about your case to enforce the law against you and to basically punish you for being noncooperative during their investigation and in most cases, but I would say in all cases but as an attorney, I cannot say ‘in all cases’, in the vast majority of cases, let’s put it this way. In the vast majority of cases, the best strategy is the one that is adapted to the facts of the case. In the vast majority of these cases, the strategy is one of cooperation, honesty, disclosure but strong defense of your position. Ethical defense. Logical defense. Defense that does not offend the IRS personally but the one that states your position in the logical, legally, justified way.
You want to have a cordial relationship with the IRS agent. You want the IRS agent to understand that you are not a criminal; that you are not a person who lies. You want them to trust you with respect to what you tell them. They want to trust your ability to deliver on what you promised to deliver.
The strategy that is based on lying to the IRS, hiding from the IRS, swearing at the IRS, fighting them at every point whether it is necessary or not necessary is completely wrong. This is not to say that your defense should not be strong, of course, you must always strongly defend your position as long as it is a justifiable position. There are certain points that sometimes are better to be conceded and explained. The defense of your case will be based on a strategy, not on hostility to the IRS, because hostility to the IRS is usually a counterproductive way to conduct and IRS audit. As I’ve said: cordial, polite but a strong defense; you will have your position, you will have your facts and this position and these facts should form the basis of your defense against the IRS.
If you would like to learn more about an IRS audit, and if you’d like to secure my help with respect to your defense in an IRS audit, you can call me at (952) 500-8159 or you can email me at [email protected]
You can call me at (952) 500-8159 or you can email me at [email protected]
Thank you for watching, until the next time.
IRS Audit Preparation With Annual Tax Compliance | IRS International Tax Audit Lawyer San Antonio
/in International tax attorney & lawyer Video /by adminHello and welcome to Sherayzen Video Blog. My name is Eugene Sherayzen and I’m an international tax attorney and owner of Sherayzen Law Office, Ltd.
Today, I’m continuing my series of blogs from San Antonio, Texas. In this series of blogs, I discuss issues related to IRS audits. In the previous video, I mentioned that the Inflation Reduction Act provided a humongous sum of money to the IRS to hire new IRS agents to conduct field audits. In fact the IRS said that it has plans to increase its staff by 40,000 people; this is an enormous amount of people. This means that the capacity of the IRS to audit US taxpayers is going to increase manifold.
In the previous video, I also mentioned that it is important for taxpayers to start preparing for an IRS audit before it actually happens. What does it mean to be preparing for an IRS audit? First of all, the preparation for an IRS audit must begin before a tax return is ever submitted, meaning that all tax positions that you are taking should be well documented and even better, if they’re not only documented but also disclosed to the IRS. That is do not take a position, with respect to a tax issue and not disclose it to the IRS. If the IRS later disagrees with you, they may think that you actually did it intentionally or tried to hide something. In this case, in order to avoid this issue, it is better to basically disclose it in a small statement saying, for example, “based on the IRC section internal revenue code, we’re taking the position that this and this and this must happen”. That’s it; a small statement, you don’t have to provide a huge analysis, just disclose it to the IRS either as an IRS audit at that point, the IRS cannot claim willfulness in your approach as long as your position is reasonable of course, based to a degree on certain facts.
Preparation for an IRS audit must happen already when the tax return is being prepared and submitted to the IRS; that’s the first stage.
The second stage is to get supporting documentation, organize it and that means not only getting the bank statements or statements from your broker but it also means getting the statements from third parties in support for your position – that’s the second stage of preparation.
The final stage of the preparation for an IRS audit involves saving all of that information; that is very important. Many people think that once they have prepared everything and put everything together, that it is enough. In reality, there may be years before an IRS audit happens and if you do not have this information, you will not be able to prove to the IRS that you once had it. Please make sure that you safeguard the information related to a possible audit.
In the next video, I will discuss how an IRS audit begins.
Thank you for watching, until the next time.