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Category: Planning for Tax Minimization

The IRS Removes the ‘Willfulness’ Checkbox from Voluntary Disclosure Applications

25 June, 2025

The IRS is to remove the “willfulness” checkbox from Form 14457, the Voluntary Disclosure Practice Preclearance Request and Application. For years, the Voluntary Disclosure Practice has been an important corrective mechanism for taxpayers who have

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Tax Advisors: New Jersey Man Pleads Guilty to Tax Evasion Through Asset Concealment

12 June, 2025

Tax advisors should take note of the guilty plea last week by Matthew Tucci of West Long Branch, New Jersey, in a significant tax evasion case. This case serves as an illustration of the IRS’s

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Still Waiting for Your Employee Retention Tax Credit?: ERC Refund Lawsuits

9 May, 2025

The Employee Retention Tax Credit (ERC) was established to provide financial relief to businesses affected by the COVID-19 pandemic. However, numerous companies are still awaiting their ERC refunds due to prolonged IRS processing times. With

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Parag Patel Esq. Speaks at Annual Convention of New Jersey Society of Certified Public Accountants

28 March, 2025

Parag Patel Esq. will be a featured speaker at the annual state convention of the New Jersey Society of Certified Public Accountants (NJCPA) on June 3-6, 2025 in Atlantic City, NJ. The seminar is entitled

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Navigating the Puzzle: Understanding Form 8938 Audit Triggers

21 March, 2025

It’s important to be aware of the caution and risks associated with foreign banks reporting balances to the IRS, particularly in the context of Form 8938 compliance. While Form 8938 audits are very rare, below

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Navigating Inheritance: The Step-Up in Basis and Recognizing Implied Life Estates After Death

18 March, 2025

Understanding the Step-Up in Basis Under Internal Revenue Code Section 1014(a), the basis of inherited property is stepped up to its fair market value (FMV) at the time of the decedent’s death. This means that

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Parag Patel Esq. is a featured speaker at the National Association of Enrolled Agents (NAEA) Basic Foreign Certificate Program

15 March, 2025

Parag Patel Esq. is a featured speaker at the National Association of Enrolled Agents (NAEA) Basic Foreign Certificate Program event In June 2025. The multi-day educational event focused on international taxation for tax professionals. Mr.

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Navigating IRS Form 3520 Part IV for Audit Scrutiny for Foreign Gifts and Inheritances

7 March, 2025

IRS Form 3520, a critical international compliance document, requires meticulous attention, particularly Part IV, which involves the receipt of substantial foreign gifts and inheritances. For advisors, understanding the specific audit triggers associated with this section

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The Impact of DOGE Cuts on IRS Tax Audits and Investigations

24 February, 2025

Tax professionals may be assessing whether the Department of Government Efficiency (DOGE) under the Trump administration will affect ongoing (and future) IRS audits and investigations. Recent highly publicized changes suggest a substantial impact. The termination

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Beware the Hawala Network: Tax and Legal Risks

22 February, 2025

Hawala is a method of transferring money without any physical money actually moving. It is described as a “money transfer without money movement.” Hawala is used as an underground remittance network that exists outside of

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Dangers of Using Cash to Pay Wages

15 February, 2025

The IRS closely monitors businesses paying wages in cash for potential employment tax violations. Under IRC § 3402, employers must withhold and remit payroll taxes, and failure to do so can result in Trust Fund

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Conservation Easements: A Dangerous Tax Deduction

8 February, 2025

The IRS is aggressively targeting conservation easements, calling them abusive tax shelters and pursuing audits, penalties, and even criminal charges. Taxpayers who claimed deductions could face full disallowance, massive fraud penalties, and potential prosecution. Promoters,

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Recent Posts

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  • Criminal Tax Enforcement Takes Center Stage: The National Fraud Enforcement Division MemorandumAugust 21, 2026
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  • Navigating the US Estate Portability Election: Strategic Timing and Compliance Procedures for Form 706July 13, 2026
  • IRS Transitions from First Time Abatement to Automated Penalty Relief: Strategic Impacts for Tax AdvisorsJuly 11, 2026
  • Parag Patel to Present on IRS Foreign Asset Enforcement at the 2026 NATP TaxposiumJuly 9, 2026

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