IRS Extends Late Portability Election Automatic Relief from 2 to 5 Years

- By : Parag Patel

filing threshold in Internal Revenue Code Section 6018(a)) to make a late election through the second anniversary of death. The IRS stated in Rev. Proc. 2022-32 that, even since it…

IRS Updates Process for FAQs

- By : Parag Patel

…stating that it will retain prior versions if you rely on an IRS FAQ for a position, we recommend printing out the IRS FAQ and filing it away, at least…

Using the 65-day rule as an opportunity for income tax savings for estate

- By : Parag Patel

…to $466,950 for a couple married filing jointly (MFJ). So the highest tax rates are paid starting at extremely low-income levels, which leads to very high income tax. Net investment…

FBAR Deadline Extended to December 31, 2021

- By : Parag Patel

The Financial Crimes Enforcement Network (FinCEN) today issued a notice extending the filing date of Reports of Foreign Bank and Financial Account (FBARs) for victims of recent natural disasters, including…

New Jersey Transfer Inheritance Tax : How the Tax Works

- By : Parag Patel

…dying after 12/31/01 leaving estates valued less than $675,000, the transfer of real estate can normally be effectuated by the filing of form L-9, Real Property Tax Waiver. The L-9…

Is my trade or business a “Specified Service Trade or Business” and is my taxable income more than the amount that permits me to have a full 20% Section 199A deduction?

- By : Parag Patel

…CPI modified limits of $160,700 in 2019 for a single person, or $321,400 in 2019 for a married couple filing jointly. The deduction is reduced on a sliding scale so…

Latest Guilty Plea for an Another HSBC Offshore Bank Accountholder

- By : Parag Patel

…not to, instead silently filing his forms. According to the criminal information and plea agreement, on Oct. 6, 2009, following widespread media coverage of UBS’s disclosure to the IRS of…

FBAR Deadline Slightly Extended

- By : Parag Patel

…Bank Secrecy Act (BSA) E-Filing System had been extended from Oct. 15, 2020, to Dec. 31, 2020 (all FBARs must be e-filed). However, on Thursday that notice was no longer…

Checklist of tax forms for taxpayers with foreign assets

- By : Parag Patel

…various types of investment accounts, and potentially other assets such as rental properties and foreign insurance policies. Form 8938 also differs in that it’s included along with your 1040 filing

Should I close my foreign account?

- By : Parag Patel

…voluntary disclosure program and paying a 27.5 percent penalty on your highest account balance? At tax return filing time, should you check the box on Schedule B noting that you…

Opting-out of the Offshore Voluntary Disclosure Initiative: FBAR Penalty Mitigation Guidelines

- By : Parag Patel

filing the FBAR . To Qualify for Level IV If the maximum balance of the account to which the violations relate at any time during the calendar year exceeded $1…

Watch Out: The NJ Inheritance Tax

- By : Parag Patel

…the decedent. When filing an Inheritance Tax return, Form IT-R should be used for resident decedents, and Form IT-NR should be used for nonresident decedents. In addition to the inheritance…

Foreign mutual funds = Passive Foreign Investment Companies (PFICs)?

- By : Parag Patel

…Companies” (PFICs), which is often a surprise to our clients. U.S. persons who own foreign mutual funds can sometimes be in for an unpleasant surprise when it comes to filing

Upcoming 2013 Tax Provisions Which Will Impact Planning Opportunities

- By : Parag Patel

…income over $200,000 for single taxpayers, $125,000 for married taxpayers filing separately, and $250,000 for married taxpayers filing jointly. In spite of the uncertainty, our tax law firm is helping…

2012 Offshore Account Criminal Tax Cases

- By : Parag Patel

…to a defense filing in which his lawyers asked that he not be imprisoned. Heller previously had agreed to pay a fine of nearly $10 million for hiding $26 million…

Top FBAR Reporting Error

- By : Parag Patel

…or bequests from their foreign parents are simply unaware of their FBAR filing obligations. Despite well-publicized enforcement actions against financial institutions and individual account holders, as well as corresponding amnesty…

INHERITANCE TAXES IN NEW JERSEY RATES

- By : Parag Patel

…estate tax return be filed with the Inheritance Tax Branch within 30 days after the filing of the original with the Federal government. Also, the Branch must receive a copy…

Tax Changes Due to the Election

- By : Parag Patel

…to 37% in 2018. For the 2020 tax year, this top marginal rate is applicable to earned income above $518,400 for single filers and over $622,050 for married couples filing

65 Day Election on March 6, 2023

- By : Parag Patel

…and Trusts). If no return is required to be filed for the taxable year of the trust for which the election is made, the election is made by filing a…

Foreign HSBC Bank Customer Avoids Jail: Given Three Years’ Probation

- By : Parag Patel

…to the Internal Revenue Service. Arvind Ahuja was sentenced yesterday in federal court in Milwaukee, where he was convicted Aug. 23 of filing a false tax return and failing to…

2020 New “Universal” Deduction for Charitable Contributions

- By : Parag Patel

…a provision allowing people to deduct $300 for charitable contributions. The $300 limit applies per tax-filing unit, so for those who file married filing jointly, the maximum above-the-line deduction is $300. Taxpayers can…

Interesting 2023 Foreign Account Cases

- By : Parag Patel

…English did not willfully fail to file FBAR reports as his accountant mistranslated the English instructions into Japanese such that he believed that the filing was only required by U.S….

IRS Letters and Notices Offering an Appeal Opportunity

- By : Parag Patel

…Non-filer Letter This letter advises you the IRS believes you are liable for filing tax returns for the periods identified in the letter. It includes a report giving you a…

The Expensive NJ Inheritance and Estate Tax

- By : Parag Patel

…real property owned by the decedent. When filing an Inheritance Tax return, Form IT-R should be used for resident decedents, and Form IT-NR should be used for nonresident decedents. In…

US Court finds non-willful FBAR penalty not limited to $10,000 per year

- By : Parag Patel

…ruling, taxpayers with unreported foreign financial accounts should consider entering one of the IRS’ voluntary disclosure programs, such as the Streamlined Domestic Offshore Procedure. Noncompliant taxpayers are strongly recommended to…

2011 Offshore Voluntary Disclosure Initiative Frequently Asked Questions (FAQs) and Answers

- By : Parag Patel

We have reviewed the new 2011 OVDI FAQs and noticed that the Service has refined and streamlined the voluntary disclosure process. Our firm prepared dozens of voluntary disclosure applications in…

President Trump Revamps the IRS through his 2019 Taxpayer First Act

- By : Parag Patel

…information sought is narrowly tailored and closely related to the tax noncompliance, and it identifies a specific tax law violation. It is unlikely that this additional IRS burden will significantly…

Foreign Gift Received: Form 3520 Penalties Eliminated in New Court Case

- By : Parag Patel

…from income (correct) and that no filings were required (incorrect). After realizing his mistake, Mr. Wrzesinski contacted a tax attorney (not me) and filed a reasonable cause statement under the…

Living Wills in New Jersey

- By : Parag Patel

…community living, and the use of assisting devices. Health care institutions must establish procedures and practices for resolution of the disputes among the patient, and “Health Care Representative” and attending…

Parag Patel to be Speaker for Estate Administration at Practicing Law Institute’s NJ Basic CLE Marathon 2021

- By : Parag Patel

…attorneys practicing in Estate Administration and probate matters seeking to learn about probate procedures, including New Jersey-specific instruction and tax minimization. Topics to be covered include: * Managing the estate…