Parag Patel

IRS Notice CP 503: IRS Second Notice of Balance Due: What to Do

11 Nov 17

An IRS CP 503 notice is a letter that the IRS sends out to individuals as a reminder and a means to collect on a tax debt balance. This letter is a final notice and follows previous attempts to receive

IRS Announces New Investigative Units

07 Nov 17

In a press call on August 2, 2017, the Chief of the Internal Revenue Service’s (IRS) Criminal Investigation Division (“IRS-CI” or CID), John D. Fort, announced two new enforcement initiatives: a National Coordinated Investigations Unit and an International Tax Enforcement

Taxpayer Tips: Best Practices for U. S. Tax Court

26 Oct 17

Taxpayers contesting IRS assessments of additional taxes, penalties and interest have a number of different options to contest and appeal those assessments. One of those options includes bringing a case to the United States Tax Court (Tax Court). Here are some Tax

Beware IRS Forms W-8

09 Sep 17

Over the past few months we received many inquiries from clients and parties asked by companies to complete IRS Form W-8. Beware Form W-8 is generally filled out by foreign non-US entities or persons (citizens and corporations) in order to

Powerful Post-death Planning Strategies for Trusts and Estates

08 Sep 17

After a client passes away, there is much more to do than just prepare a final Form 1040, U.S. Individual Income Tax Return. Taking control of the postmortem planning process can be a powerful way to save tax dollars for

New Court Case Limits the Reasonable cause exception to FBAR penalties

03 Sep 17

Taxpayers across the country rely on advice from their accountants and CPAs to meet the complicated requirements of the U.S. Tax Code. But a new case, Jarnagin v United States, in the U.S. Court of Federal Claims suggests that CPA

IRS Releases New IRS Form W8-BEN: U.S. persons beware of completing such form at the request of a third party

10 Aug 17

The long awaited revised IRS Form W8-BEN has been recently released in July 2017. The major changes to IRS Forms W8, particularly W-8BEN-E (which is still in draft form), have been driven by the changes in the law under FATCA. The new IRS

New IRS practice unit: “Substantial compliance” doctrine, international information return penalties

29 Jun 17

The IRS Large Business and International (LB&I) division last week publicly released a “practice unit” that addresses what the term “substantially complete” means with reference to international information return penalties, particularly Form 5471. The IRS recently released a new International Practice

U.S. Taxpayers at New Risk of Audit from OVDP Declines and Withdrawals Campaign

19 Jun 17

Last year, the US Treasury Inspector General for Tax Administration (TIGTA) released a report which assessed how well that IRS was managing the Offshore Voluntary Disclosure Program (OVDP). OVDP is one of the programs taxpayers may use to become compliant

FATCA Noncompliant Accounts may be Frozen or Blocked

09 May 17

Many of our clients with foreign accounts have received FATCA letters. The letters seek personal information regarding the account holder in order to comply with the US FATCA law. In recent weeks, government authorities in a few foreign countries have

Complicated Form 5471 filing requirements simplified for dormant foreign corporations

28 Apr 17

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. IRS Revenue Procedure 92-70, specifies specific, conditions

U.S. Tax Court: What to Expect

26 Apr 17

Reasons to Take Your Matter Before the United States Tax Court: You’ve recently undergone an audit or examination. You have taken the proper administrative steps to argue your case but still receive a notice of deficiency or notice of determination