Personally, I use whatever fits in the context. I would say "He died on 1 Jan 1900 and was buried at the Union Cemetery on 4 Jan...." But, if I have a separate paragraph for burial, it might say something like "and he is buried in the family plot at Union Cemetery."
There is a problem with those who WERE buried in a particular place but are no longer buried there. Perhaps there was a disinterment and the body was moved to another cemetery, or, as often happened in Europe, he was buried, but the body was dug up and the grave was recycled, with his bones being placed in a charnel house. I think that has to be explained in the Bio.