Patel Law Offices Blog
Article Discusses Termination of Offshore Voluntary Disclosure Program (OVDP) and the Streamlined Filing Compliance Procedures (SFCP)
The Internal Revenue Service (IRS) currently offers non-compliant US taxpayers several different relief programs in which to report foreign assets and/or income and become compliant with US rules related to the disclosure of foreign assets. One option is the Offshore
Income Taxation of FMLA Claims
The Family Medical Leave Act requires employers with 50 or more employees to grant 12 weeks of unpaid leave to an employee in the event of a birth, adoption or serious health condition — whether it’s the employee or someone
Happy Birthday Streamlined Filing Compliance Procedure!
The Streamlined Filing Compliance Procedure (SFCP) was “born” two years old. Two 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
Foreign mutual funds = Passive Foreign Investment Companies (PFICs)?
We have had many clients with unreported foreign mutual funds. As a result, it is time to revisit the unfavorable topic of foreign mutual funds as a “Passive Foreign Investment Companies” (PFICs), which is often a surprise to our clients. U.S.
How to Respond to an IRS CP3219N Notice of Deficiency (90-day letter)
Under Sec. 6212(a) the IRS can issue a statutory notice of deficiency, also known as a 90-day letter, when it determines a deficiency in an income or estate and gift tax liability. A 90-day letter is a formal legal notice,
New Trust Law Enacted in New Jersey
On January 19, 2016, the New Jersey Uniform Trust Code (NJUTC) was enacted into law. The new law will take effect on July 17, 2016. The new law, based in part on model legislation prepared by the Uniform Law Commission,
US Entities with foreign assets have more information reporting
The US Treasury has issued long-awaited regulations specifying the domestic taxpayers who have to disclose substantial foreign financial assets to the Internal Revenue Service (IRS) every year. The new rules, effective immediately, are linked to the Foreign Account Tax Compliance
The Tax Heat is On
At the recent American Bar Association meeting held on January 29, 2016, the acting Attorney General for the tax division disclosed that the IRS and US Department of Justice are now focusing bank investigations in Belize, the British Virgin Islands,
Becoming Un-American: Record number of US citizens renounce their US citizenship
A record 4,279 people renounced their U.S. citizenship or long-term residency in 2015, according to new data released by the Treasury Department. Last year was the third year in a row that renunciations have increased to record levels and the
New IRS Forms Informs Beneficiaries of Asset Basis Values
Instructions to IRS Form 8971 for reporting the asset basis of estates have now been finalized. Form 8971, Information Regarding Beneficiaries Acquiring Property From a Decedent, tells estate executors and others required to file a Form 706 how to report
US real property now more attractive for certain foreign investors
On 18 December President Obama enacted the Protecting Americans from Tax Hikes (PATH) Act of 2015, extending several temporary tax relief provisions either permanently or for two or five years. PATH also amends the Foreign Investment in Real Property Tax
New law complicates US Passport issuance
Pending legislation, H.R. 22 called Developing a Reliable and Innovative Vision for the Economy (DRIVE) Act, is likely to be passed law next month. This law will have major implications for those with federal tax debts wishing to apply for
Answers to Common Questions for IRS CP3219N Notice of Deficiency (90-day letter)
What you need to do If you want to challenge the deficiency determination, file a petition with the Tax Court. File your tax return immediately (no later than 90 days from the date of the CP3219N), or accept our proposed
IRS Announces New Statistics Regarding Voluntary Disclosures
Since the initiation of the U.S. Internal Revenue Service’s (IRS) Offshore Voluntary Disclosure Program (OVDP) which originally began in 2009 and the Streamlined Filing Compliance Procedures first offered on September 1, 2012, the IRS recently reported that more than 54,000 taxpayers have come forward
Top myths of US tax compliance for Foreign Accountholders
There is a lot of misinformation so we decided to debunk the top myths of US tax compliance. Myth #1: I don’t have to file US taxes if I live abroad. The US is one of the few countries who
Offshore Compliance Programs Generate $8 Billion; IRS Urges People to Take Advantage of Voluntary Disclosure Programs
The IRS issued the below interesting press release last week… IR-2015-116, Oct. 16, 2015 WASHINGTON — With more than 54,000 taxpayers coming in to participate in offshore disclosure programs since 2009, the Internal Revenue Service today reminded U.S. taxpayers with undisclosed
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