There are several tax proposals that are under Congressional consideration, and the Biden administration released information concerning his proposal, the “American Families Plan.” The U.S. House Ways and Means Committee released proposed budget reconciliation legislation on September 13, 2021. The
The Financial Crimes Enforcement Network (FinCEN) today issued a notice extending the filing date of Reports of Foreign Bank and Financial Account (FBARs) for victims of recent natural disasters, including Hurricane Ida, the California Wildfires, and Tropical Storm Fred. Victims
An unprecedented leak of financial records known as the Pandora Papers has revealed the offshore financial assets of dozens of current and former world leaders and hundreds of politicians from Asia and the Middle East to Latin America. The International Consortium of Investigative
We are members of the American Bar Association Section of Taxation, which on September 28, 2021 submitted comments to the IRS on the IRS Voluntary Disclosure Program (“VDP”), the Streamlined Domestic Offshore Program (“SDOP”), and the Streamlined Foreign Offshore Program (“SFOP”). In the
Yesterday the US Department of Justice announced here the indictment of Mark Anthony Gyetvay, who filed to enter IRS “Streamlined Filing Compliance Procedures in which he attested that his prior failure to file FBARs and tax returns was non-willful.” Apparently, his Streamlined
Parag Patel Esq. speaks at New Jersey Society of Certified Public Accountants (NJCPA) Webinar “What Tax Professionals Should Know About Trusts and Estates: Estate Tax Reform and the 2021 Planning Window”.
Parag Patel Esq. will be a featured speaker at a virtual New Jersey Society of Certified Public Accountants (NJCPA) Webinar panel entitled “What Tax Professionals Should Know About Trusts and Estates: Estate Tax Reform and the 2021 Planning Window”. Mr.
Upcoming live video webinar: U.S.-India Tax Planning: Reporting Issues, Traps to Avoid, Tax Treaties, FTC, FACTA/FBAR Reporting, Passive Income
I am pleased to announce that I will be speaking in an upcoming Strafford live video webinar, “U.S.-India Tax Planning: Reporting Issues, Traps to Avoid, Tax Treaties, FTC, FACTA/FBAR Reporting, Passive Income” scheduled for Thursday, October 21, 1:00pm-2:30pm EDT. Our panel will provide
Parag Patel Esq. presents new tax law changes at Broward Chapter of The Florida Society of Enrolled Agents (FSEABC) Webinar
Parag Patel Esq. will be the main speaker at a virtual Broward Chapter of The Florida Society of Enrolled Agents (FSEABC) Webinar panel entitled “Upcoming federal tax law changes: What to Expect”. Mr. Patel will discuss the new tax changes
The IRS quietly created new procedures for Streamlined Filing Compliance Procedures earlier this month relating to filings with “transition tax” due under Internal Revenue Code Section 965. The new procedures apply to Streamlined Domestic Offshore submissions and Streamlined Foreign Offshore
Do FBAR penalties survive death? According to a new court ruling, the answer is clearly yes (unfortunately). In United States v. Gill, 2021 U.S. Dist. LEXIS 12203 (S.D. Tex. 6/30/21), the court ultimately held that an FBAR nonwillful penalty survives
All U.S. citizens and permanent residents are required to annually file a U.S. income tax return reporting their worldwide income from all sources. Additionally, U.S. citizens and permanent who have an interest in or signatory authority over foreign bank and
In the midst of tough tax season, many U.S taxpayers are unfortunately surprised to discover that they have a U.S. tax reporting obligation on financial accounts or assets held overseas. Once they discover their tax and reporting obligation, there are
The reporting requirements for IRS Form 5471 are complex, including ‘category of filer’ and required schedules. However, very few taxpayers know that there are special simplified filing rules for a foreign dormant corporation. Although not widely published, IRS Revenue Procedure
The Streamlined Filing Compliance Procedure (SFCP) was “born” six years ago. Six years ago the IRS publicly announced the SFCP, which has been used by many non-compliant US taxpayers with the disclosure of foreign assets. SFCP has two sub-programs: one
The IRS Streamlined Domestic Offshore Program (“SDOP”) allows eligible U.S. Taxpayers who failed to disclose foreign financial accounts to voluntarily disclose their conduct to the IRS and pay a reduced penalty. However, to be eligible for the SDOP program, the
In a recent court case, a court found that “willfulness” in the context of civil FBAR penalties is satisfied by recklessness and does not require disregard of a known legal duty. In United States v. Horowitz, (4th Cir. Oct.
When receiving a penalty for failure to timely file Form 3520, Notice CP 15 or CP 215 is sent to the taxpayer notifying the taxpayer which requires a timely response. When receiving Notice CP 15 or CP 215 a Taxpayer
When a U.S. person receives a gift from a foreign individual, corporation, partnership, or estate which is treated as a gift or bequest and excluded from gross income, the recipient may be required to file Part IV of Form 3520.
For years, the government has known about the widening tax gap, which reports uncollected taxes among US taxpayers. However, typically, the government does not do much to address the increasing loss of tax revenue. It appears that is about to
We expect taxes to increase. The big question however is when the increase(s) will take effect. Although it is politically unpopular and unfair to change tax laws after people rely on them in making transactions through the year, legally (and
Many of our clients have recently received IRS Letter 6185, which begins with “Why we’re writing to you: We received information that you held an interest in one or more foreign financial accounts, foreign entities, or foreign financial assets.” This
The US Treasury Inspector General for Tax Administration (TIGTA), in two recent reports, said that the IRS collected more tax revenue in 2019 than in any other previous year but, at the same time, overlooked high-income delinquent taxpayers and so
The U.S. Court of Appeals for the Ninth Circuit today—in a case of first impression for the circuit—held that the IRS is limited to imposing one penalty for the untimely filing of a single accurate “Report of Foreign Bank and