Patel Law Offices Blog
Foreign Gifts and the Uncommon Form 3520: A Trap for the Unwary
We have had several clients recently subject to Form 3520 penalties, so we thought we would remind everyone of the need to timely file these forms when receiving a foreign gift. When a U.S. person receives a gift from a
Parag Patel Esq. Speaks at NJCPA Seminar on”Criminal Tax: What Tax Professionals Need to Know to Help Clients and Themselves”
Parag Patel Esq. will be a featured speaker this month at a New Jersey Society of Certified Public Accountants (NJCPA) Seminar entitled “Criminal Tax: What Tax Professionals Need to Know to Help Clients and Themselves” Seminar descriptions is below: “Criminal
Parag Patel Esq. speaks at NJCPA Seminar ” Federal Tax Update and Latest Tax Controversy Hot Topics”
Parag Patel Esq. will be a featured speaker this month at a New Jersey Society of Certified Public Accountants (NJCPA) Seminar entitled ” Federal Tax Update and Latest Tax Controversy Hot Topics“. Seminar descriptions is below: Federal Tax Update and
Parag Patel Esq. speaks at the National Association of Enrolled Agents
Parag Patel Esq. is a featured speaker at the National Association of Enrolled Agents (NAEA) Estate and Gifts Certificate Program on November 7, 2023. Mr. Patel will speak on Estate Planning strategies and developments. The seminar description is below: Course
IRS Investigating Employee Retention Credit (ERC) claims
The IRS continues to warn businesses not to fall for aggressive marketing or scams related to the ERC. Businesses should first check with their trusted tax professional before submitting an ERC claim. As part of a larger effort to protect
Owner of Iberia Restaurants in Newark Found Guilty of Tax Crimes
The failure to file and pay payroll taxes has been a major focus of IRS investigations in the past few years. Sometimes the cases are civilly examined, but occasionally the government criminally prosecutes more willfull taxpayers. A New Jersey man
IRS Has Ended Unannounced Visits to Collect
The IRS is drastically cutting back on its decades-long practice of surprising taxpayers at their homes or businesses because of concerns about the safety of employees and confusion caused by scam artists who also knock on doors. The duties of
The Unknown Tax: New Jersey Inheritance Tax
While the New Jersey Estate Tax was abolished 5 years ago and the Federal Estate Tax applies to taxpayers with estates over $12 million, the NJ Inheritance tax is relatively unknown and impacts thousands of modest taxpayers every year. The
Parag Patel Esq. speaks at NJCPA Tax Seminar: “Under the IRS Microscope: International Tax Reporting Update” and “What Tax Professionals Should Know About Trusts and Estates”
Parag Patel Esq. will be a featured speaker at a virtual New Jersey Society of Certified Public Accountants (NJCPA) Webinar panel entitled “Under the IRS Microscope: International Tax Reporting Update” and “What Tax Professionals Should Know About Trusts and Estates”.
Watch Out: IRS Audits of ERC Claims Expected
The IRS has begun to audit ERC refund claims filed for 2020 and 2021. While the audit process is just starting, it is expected to increase over time as the IRS has indicated it is interested in auditing ERC claims.
New Mandatory E-filing Form 8300 for Reporting of Large Cash Currency Transactions
The IRS announced yesterday that certain businesses that receive payments of over $10,000 in cash must file Form 8300, Report of Cash Payments Over $10,000 Received in a Trade or Business, electronically starting in 2024, the IRS said in a news release (IR-2023-157).
IRS Uses New Funding to Target US Persons with Malta Accounts
The US Treasury and US Internal Revenue Service are to leverage more resources to detect Americans using Malta personal pension accounts to claim tax exempt income, it said in a statement last week. The additional resources to investigate the Malta
NJ Contractor Charged with Criminal Tax Evasion for Unreported Checks
A Union County NJ contractor was arrested last week for tax evasion for not reporting cashed check income. Joel Konopka, 45, of Elizabeth, New Jersey, is charged by indictment with four counts of corporate tax evasion, two counts of filing
Beware the New 2023 Form 1099-K
Beginning in 2023, third-party payment networks must file Form 1099-K with the IRS and provide a copy to the taxpayer when the gross payment amount exceeds $600. However, not all payments from third parties are taxable. Taxpayers can take steps to prevent non-taxable items
IRS FBAR Penalties Are Now Unmitigated
The Internal Revenue Service will no longer reduce the penalty for taxpayers who non willfully fail to file Reports of Foreign Bank and Financial Accounts (FBAR or FinCen 114), according to recent Internal Revenue Service (IRS) internal guidance. The IRS
IRS Targets Puerto Rican Residency Transactions
In a July 14, 2023, release, the IRS stated that “[t]hanks to Inflation Reduction Act resources,” it has begun a criminal crackdown on Act 20/22/60 participants engaging in a ”[h]igh-dollar scheme in Puerto Rico.” The IRS has “identified about 100
IRS Aggressively Starts New Criminal Investigations
The IRS announced last week in a press release that it is taking “swift and aggressive action” to strengthen enforcement efforts against high-income individuals as it uses the new budget funding it recently received. Recent enforcement efforts include closing about
Malta Pension Plan Being Investigated by IRS Criminal Investigation Division
The Malta Pension Plan is a tax-favorable pension plan that has been used by U.S. taxpayers in Malta. The plan allows for significant tax savings, as gains on assets contributed to the plan are not subject to tax in Malta
National Taxpayer Advocate Fights for FTA Penalty Relief from the IRS
National Taxpayer Advocate Erin M. Collins today released her statutorily mandated midyear report to Congress. The report says the tax-return filing season generally ran smoothly this year, urges the Internal Revenue Service to prioritize a broad array of technology upgrades, and
How to Avoid Employee Retention Credit (ERC) Scams
A small industry of specialist firms has sprung up to help business owners claim the Employee Retention Credit (ERC), a governmental tax incentive intended for companies stressed by the pandemic. But businesses need to be careful not to get scammed. Promoters
Watch Out: Malta Pension Plans Become Listed Transaction
Last week, in a government notice of proposed rulemaking (REG-106227-22), US Treasury and the IRS issued proposed regulations that identify any transaction that is similar to a Malta personal retirement scheme as a “listed transaction.” A listed transaction is a
Beware Expected Employee Retention Credit (ERC) Audits
The IRS recently issued its seventh warning against questionable ERC activity. The IRS, with its new funding, is expected to ramp up its Employee Retention Credit (ERC) audit enforcement. The IRS ERC audit process is complex and can be daunting
Parag Patel Esq. Speaks at Annual Convention of New Jersey Society of Certified Public Accountants
Parag Patel Esq. will be a featured speaker next week at the annual state convention of the New Jersey Society of Certified Public Accountants (NJCPA) in Atlantic City, NJ. The seminar is entitled “ Hot Topics in Tax Controversy.” Mr.
Parag Patel Esq. Speaks to New Jersey Society of Certified Public Accountants (NJCPA) Nonprofit Interest Group
Parag Patel Esq. was the featured speaker last month at a New Jersey Society of Certified Public Accountants (NJCPA) Nonprofit Interest Group. The Group is a resource for NJCPAs for accounting and auditing issues affecting Not-for-Profit organizations providing interpretations of
What is a Mark-to-Market (MTM) election for a Passive Foreign Investment Company (PFIC)?
Several clients have recently asked us about the Mark-to-Market (MTM) election for a Passive Foreign Investment Company (PFIC). A MTM election for a Passive Foreign Investment Company (PFIC) is an option that allows a taxpayer to treat their investment in
Comments on IRS Form 3520 to Report Foreign Gifts
The Florida Bar Tax Section recently made some excellent comments in response to the Internal Revenue Service’s request for comments concerning Forms 3520 and 3520-A. The comments were intended to enhance the quality, utility, and clarity of the information to
REPORTING FOREIGN ASSETS & ACTIVITIES: REQUIREMENTS AND CHALLENGES: Complimentary CPE Presentation
Join us for a Complimentary CPE Presentation on Reporting Foreign Assets & Activities: Requirements and Challenges Penalty structure Best practices in reporting IRS penalty avoidance programs Latest Supreme Court case impacting FBAR penalties Summary of most common international tax reporting forms
Tax Court Rules IRS Cannot Assess or Collect Form 5471 Penalties
Last week the US Tax Court issued its opinion in Farhy v. Commissioner, ruling that the Internal Revenue Service (IRS) could not assess or collect penalties under Internal Revenue Code (Code) Section 6038(b) for a late-filed Form 5471 against Alon Farhy. This is a big
Foreign Gift Received: Form 3520 Penalties Eliminated in New Court Case
The US DOJ Tax Division recently conceded penalties assessed against a police officer for failing to file informational returns on for a foreign gift. Krzysztof Wrzesinski, a Polish-American citizen, had failed to file Form 3520, or the “Annual Return to
Rare Supreme Court Ruling Favors Taxpayers!
The US Supreme Court rarely hears tax cases, but this week ruled on a case in favor of taxpayers. The case was originally heard because lower courts issued conflicting opinions. This week, the Supreme Court scaled back the federal penalties
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Recent Posts
- Foreign Gifts and the Uncommon Form 3520: A Trap for the Unwary November 9, 2023
- Parag Patel Esq. Speaks at NJCPA Seminar on”Criminal Tax: What Tax Professionals Need to Know to Help Clients and Themselves” November 9, 2023
- Parag Patel Esq. speaks at NJCPA Seminar ” Federal Tax Update and Latest Tax Controversy Hot Topics” November 8, 2023
- Parag Patel Esq. speaks at the National Association of Enrolled Agents November 6, 2023
- IRS Investigating Employee Retention Credit (ERC) claims November 6, 2023
- Owner of Iberia Restaurants in Newark Found Guilty of Tax Crimes October 31, 2023
- IRS Has Ended Unannounced Visits to Collect October 17, 2023
- The Unknown Tax: New Jersey Inheritance Tax October 17, 2023
- Parag Patel Esq. speaks at NJCPA Tax Seminar: “Under the IRS Microscope: International Tax Reporting Update” and “What Tax Professionals Should Know About Trusts and Estates” October 13, 2023
- Watch Out: IRS Audits of ERC Claims Expected October 12, 2023
- New Mandatory E-filing Form 8300 for Reporting of Large Cash Currency Transactions August 31, 2023
- IRS Uses New Funding to Target US Persons with Malta Accounts August 25, 2023