Tax Law Services
We are an experienced tax law firm serving clients nationwide.Foreign Asset Planning
It is not unlawful to have foreign bank accountWills, Trusts and Estate Planning
Our law firm provides highly-personalized, responsive service to estate planning clients as we counsel them at all the critical stages of their lives.Estate Administration
The death of a loved one may be difficult enough to endure without having to worry about the ensuing estate matters.Meet Mr. Patel
Mr. Patel’s expertise is in all stages of tax controversies including international tax
law, foreign bank account
Mr. Patel is a graduate of Georgetown (J.D.) and New York University (LL.M tax) law schools, which are the top 2 tax law schools in the United States. Mr. Patel is a Board Certified Tax Law Attorney, Board Certified Estate Planning Law Specialist, Board Certified Elder Law Attorney, and frequent speaker on legal issues affecting tax, offshore tax planning, and estate planning.
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About Us
Patel Law Offices’ goal is to achieve our clients’ objectives in the most creative, responsive, and cost-effective manner.
Our International Tax Attorney team represents clients nationwide and globally in IRS offshore and voluntary disclosure solutions. We have counseled clients in over 1000 voluntary disclosure matters and are one of the most experienced IRS offshore and voluntary disclosure law firms.
Each case is led by Mr. Patel, who is a Board Certified Tax Law Lawyer. Our International Tax Attorney team concentrates in IRS offshore and voluntary disclosure solutions for undisclosed accounts, assets and investments including Streamlined Domestic Offshore
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Rahul Sharma ★★★★★
Parag provided both professional and personal advice in a super timely manner. Would definitely recommend and work with again in the future.
Janet Knoth ★★★★★
Parag is very knowledgeable and professional. He responded quickly to questions and for scheduling appointments. We have had documents prepared for our business as well as estate planning for our family. I highly recommend his services, his guidance was very beneficial to our family both legally and financially.Latest Blog Posts
Caution: Increased FBAR Enforcement
The last month or so has unfortunately seen a lot of FBAR enforcement court rulings against US taxpayers and in favor of the government. The Financial Crimes Enforcement Network (FinCEN) of the Department of the Treasury can levy high penalties for each year that a timely Form FinCEN 114…
Tax Changes Due to the Election
Many Tax Changes Expected At the time of this writing, the political conventions are over, and Joe Biden has a double-digit lead in some polls. A number of Senate seats may turn blue as well, and this could give the Democrats a majority in Congress. If all that was to c…
FBARs from Wuhan
The US Department of Justice recently announced the indictment for tax-related crimes of Dr. Charles Lieber, the former Chair of Harvard University’s Chemistry Department, for monies received from a university in Wuhan, China. Key excerpts from the announcement are: Dr. Charles Lieber, 61, was indicted by a federal grand jur…
Foreign Retirement Plans: New IRS Exemption from Required Information Reporting on Forms 3520 and 3520-A
In recent IRS Revenue Procedure 2020-17, the IRS has created a procedure where certain U.S. persons having an interest in tax-favored foreign trusts established and operated exclusively or almost exclusively to provide pension or retirement, medical, disability, or educational benefits are exempt from Forms 3520 and 3520-A reporting. U.S. perso…
Common Problems Solved
Streamlined Domestic Offshore Procedures (SDOP)
The Streamlined
Domestic Offshore Procedures is one of the two popular programs available
under the IRS
Streamlined Filing Compliance Procedures. It is for U.S. Resident Taxpayers
who originally filed income tax returns, but were non-willful
in not reporting foreign accoun
Streamlined Foreign Offshore Procedures (SFOP)
The Streamlined
Foreign Offshore Procedures is one of the two popular programs available
under the IRS
Streamlined Filing Compliance Procedures. Applicants need not have
filed original tax returns, but they must be non-willful
in not reporting foreign accoun
Delinquent International Informational Return Submission Procedures (DIIRSP)
The DIIRSP is one of the four methods for taxpayers with unreported offshore accounts to become compliant. Taxpayers who have failed to file certain international-related information returns including Forms 5471, 8938, 3520, 8865, 926, 5472, an 8858 can use the DIIRSP to cure the non-compliance. No penalties are applied if there is reasonable cause for the failure to file the information form and the IRS agrees. Reasonable Cause is a fact specific submission, which is based on each applicant's facts and circumstances.
Delinquent FBAR Submission Procedure (DFSP)
The FBAR is the FinCEN
Form 114, which is commonly misunderstood.
A delinquent or late FBAR is subject to very
high
penalties. The DFSP is one of the four methods for taxpayers with unreported
offshore accounts to become compliant. Taxpayers who have failed to an FBAR can
use the DFSP to
cure the non-compliance. While there is no DFSP penalty the DFSP has complex rigid
eligibility requirements. Our legal team mitigates foreign accoun
Form 8938 Penalties
A delinquent or late Form
8938 Statement of Foreign Financial Assets is subject to many common
mistakes and high penalties.
Our legal team cures many common Form 893
Form 5471 Penalties
U.S. owners and investors of certain foreign corporations must file a Form 5471, otherwise there are very high Form 5471 Penalties. Form 5471 is a complex form with many common mistakes. because of the expansive disclosure of corporation's assets, liabilities and equity. Our legal team can help you fix late or unfiled Form 5471 errors.