Penalties for Not Filing Form 3520
The IRS requires a U.S. person receiving a gift from a foreign individual, corporation, partnership, or estate to report by filing Part IV Form 3520. Failure to file or late, incorrect, or incomplete filing is
Expect new aggressive IRS targeted enforcement next year.
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
The big question on a tax increases is not “if” but “when”
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
The Dreaded IRS Letter 6185: “We received information that you have a foreign account”
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,
Increased IRS Enforcement Expected Against High-Income Taxpayers
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
New Favorable Court Decision: One penalty (not multiple) applies for late FBAR filing
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
Parag Patel to be Speaker for Estate Planning at Practicing Law Institute’s NJ Basic CLE Marathon 2021
Parag Patel will be a speaker on Estate Planning at the Practicing Law Institute’s (PLI) New Jersey Basic CLE Marathon 2021. Mr. Patel’s presentation will be a general introduction for attorneys practicing in estate planning matters
Parag Patel to be Speaker for Estate Administration at Practicing Law Institute’s NJ Basic CLE Marathon 2021
Parag Patel will be a speaker on Estate Administration at the Practicing Law Institute’s (PLI) New Jersey Basic CLE Marathon 2021. Mr. Patel’s presentation will be a general introduction for attorneys practicing in Estate Administration and
New IRS Relief for Taxpayers Experiencing COVID-related Difficulties
The IRS has announced new initiatives to help taxpayers experiencing Covid-related difficulties (which probably applies to most people) who have unpaid federal tax liabilities. Specifically, the IRS has announced the below relief: · The IRS
New Tax Laws Predicted
When elected, most Presidents have successfully enacted many significant tax proposals in the first two years in office. President Biden is doing things a little differently. Because of the coronavirus pandemic, Biden has divided his
Rare confluence of tax law and immigration law
A recent case highlights the rare confluence of tax law and immigration law. This week a federal grand jury indicted Lucia Andrea Gatta, with tax evasion and failing to file Reports of Foreign Bank and
The New DIIRSP: I like the old better
Late last year, the IRS revised the Delinquent International Information Return Submission Procedures (“DIIRSP”, which some people phonetically pronounce as “dersp”) to eliminate language limiting the DIIRSP to situations where the taxpayer has not failed