What to do After Receiving Notice CP 15 or CP 215 for Failure to Timely File Form 3520

- By : Parag Patel

…with protests of Form 3520 penalties. Patel Law Offices offers a free strategy session to discuss how to resolve your foreign asset problem. Conveniently schedule online today by completing our questionnaire…

New Report: Delinquent Taxpayers Could be Identified at US Border Crossings

- By : Parag Patel

…FATCA, which will require foreign financial institutions to begin reporting on the holdings of U.S. taxpayers to the IRS or else face stiff penalties of up to 30 percent on…

IRS Streamlines its Streamlined Offshore Procedures with More User Friendly Forms

- By : Parag Patel

…for the prior six tax years must also be filed. These returns must be complete and accurate, and accompanied by full payment of taxes, interest, and applicable penalties. The new…

ERC Disallowance Letters 105C Sent to Taxpayers

- By : Parag Patel

…105C aims to help ineligible taxpayers avoid audits, repayment, penalties, and interest, protect taxpayers by preventing an incorrect refund from going to an ERC promoter, and save IRS resources by…

New IRS Forms Informs Beneficiaries of Asset Basis Values

- By : Parag Patel

…form. By law such submissions must be made available to the public. Penalties Executors who intentionally disregard filing requirements or fail to file correct Forms 8971 or furnish correct Schedules…

What to Expect if the IRS Audits Your Employee Retention Credit

- By : Parag Patel

…which means you may owe additional tax and penalties. Appeal: You can appeal the audit results if you disagree. Common reasons for ERC audits: Claiming the credit on wages that…

Estate Planning When a Spouse is Confronting Health Issues (Estate Planning for the Healthy Spouse)

- By : Parag Patel

…Of The Institutionalized Spouse’s Interest In The Principal Residence to the Community Spouse The Medicaid transfer penalties do not apply to all uncompensated asset transfers. For example, under current Medicaid…

IRS delinquent FBAR submission procedure

- By : Parag Patel

…under the penalties of perjury, continue to apply. See, for example, Treas. Reg. § 1.6038-2(k)(3), Treas. Reg. § 1.6038A-4(b), and Treas. Reg. § 301.6679-1(a)(3). Taxpayers may wish to seek legal…

New FBAR Deadlines and Penalty Relief available

- By : Parag Patel

…filing signature authority FBARs on behalf of others will be able to apply for such extensions. The grant of authority to waive penalties for first-time filers is welcome news. The…

National Taxpayer Advocate Identifies OVDP Program as a Serious Problem

- By : Parag Patel

…taxpayers from voluntarily correcting FBAR violations outside of the OVD programs. Those who opted out could be subject to an examination and FBAR penalties of up to 300 percent of…

HSBC Payment of Largest Penalty and FATCA Encourages Taxpayers to Disclose

- By : Parag Patel

…with undisclosed offshore accounts, believes that FATCA and recent large penalties should encourage more U.S. taxpayers with undisclosed offshore accounts, especially held at HSBC, to come forward before the government…

Answers to Common Questions for IRS CP3219N Notice of Deficiency (90-day letter)

- By : Parag Patel

…Tax Court has simplified procedures for taxpayers whose amount in dispute, including applicable penalties, is $50,000 or less per tax year. You can find these simplified small tax case procedures…

Bank Leumi: Another Foreign Bank Recommends the IRS Voluntary Disclosure Program

- By : Parag Patel

…Under the voluntary disclosure program, Americans can tell the IRS about undisclosed income from offshore accounts, and in return possibly get reduced fines and penalties. About 38,000 Americans have taken…

A Lesson From Brown v. U.S.: A Defective Tax Refund Filing

- By : Parag Patel

…written declaration that it is made under the penalties of perjury.” The taxpayer signature requirement may only be exempted if a legal representative certifies a claim and attached evidence of…

How to Respond to an IRS CP3219N Notice of Deficiency (90-day letter)

- By : Parag Patel

…explanation of the adjustments, including additions to tax and/or penalties. Most deficiencies are resolved without a 90-day letter. However, a notice sometimes must be issued to protect the government’s interests….

Beware of Overlooked Common Overseas Tax Forms

- By : Parag Patel

…a partnership. Transactions between you and your foreign company may have to be reported on Form 926. Failing to file these forms means penalties, generally $10,000 per form. For example,…

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

- By : Parag Patel

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…

FATCA Deadlines Extended

- By : Parag Patel

…and requires foreign financial institutions to report on the assets of U.S. taxpayers to the IRS, or else face penalties of up to 30 percent on their income from U.S….

IRS Listens, and Postpones Increased Form 1099 Reporting for PayPal and Venmo

- By : Parag Patel

…and does not include the amount on his or her tax return, it will create a mismatch with IRS systems potentially triggering an IRS notice of adjustments and penalties. If…

Another foreign bank customer found guilty of foreign income under-reporting and FBAR violations.

- By : Parag Patel

…and paid all amounts due, together with interest and penalties (a common strategy known as a quiet disclosure, which failed in this case). However, federal tax law criminalizes the willful…