Search Results for: swiss program bank
Is the IRS Finally Receiving Increased Funding?
…revenue laws and other financial crimes; purchase and hire passenger motor vehicles; and provide other services. Operations Support: $25,326,400,000 Support taxpayer services and enforcement programs, including rent payments; facilities services;…
Common Issues for US-India Tax Reporting
…amnesty programs, under which a previously non-compliant individual can become compliant and avoid potentially very high penalties or criminal prosecution. However these amnesty programs generally require the taxpayer to come…
Frequent Scenarios in Offshore Voluntary Disclosures
I have frequently seen the following scenarios in working with clients to determine whether a offshore voluntary disclosure program filing (OVDP) is appropriate and how they should report foreign account….
New FBAR Court Case Makes it Easier for Taxpayers to be Deemed Willful
…recent decision by the IRS to end the Offshore Voluntary Disclosure Program on September 28, 2018. Taxpayers who wish to join the OVDP need to make complete offshore voluntary disclosures…
A limited opportunity for generous gift tax exclusions
…in lower income tax brackets, the gifting program may produce income tax savings. In addition, the gifted assets will avoid New Jersey estate tax because there is no gift tax…
Form 3520 Penalty Relief
…the IRS to implement a comprehensive remedy including penalty abatements. To its credit, the IRS announced a broad late filing administrative penalty relief program on August 25, 2022, and has…
Parag Patel Esq. Speaks to New Jersey Society of Certified Public Accountants (NJCPA) Nonprofit Interest Group
…tax and compliance requirements that apply to tax-exempt, not-for-profit entities. The program covered new tax court decisions, recent IRS publications, the latest tax legislation that will impact tax-exempt entities, IRS…
Appeals of penalties imposed during the Offshore Voluntary Opt-Out
…of the OVDI program. We expect good results for taxpayers in appeals. Patel Law Offices is a law firm dedicated to helping clients resolve complicated tax, criminal tax, and international…
The New Jersey Civil Union Act: Tax Benefits?
…a civil union can now qualify for the Property Tax Reimbursement Program designed to reimburse these persons of property tax increases. Also if a civil union member is 65 years…
Estate Planning for Families with Special Needs Children
…life of their special needs child while maintaining the child’s enrollment in essential public benefits programs. These goals can be met through the use of a properly prepared special needs…
Explore the OVDI opt-out option: Argue for Penalty Mitigation
…program penalty. We expect some successful results for some of our clients. Under IRM 4.26.16.4.5.3 (FBAR Willfulness Penalty – Willfulness) (07-01-2008) the test for willfulness is whether there was a…
IRS Publishes Useful Chart Outlining Compliance Options for Offshore Assets
…on offshore enforcement efforts and related disclosure programs has raised awareness among many U.S. citizens about tax filing and information reporting obligations”. For some of our clients, who are panicking…
Top 10 factors to consider before deciding to opt out of OVDI or OVDP
While opting out of the OVDI or OVDP amnesty programs may result in a reduction of penalties that may otherwise be assessed, the taxpayer needs to carefully weigh the numerous…
New IRS Relief for Taxpayers Experiencing COVID-related Difficulties
…relief is also available for the first time a taxpayer is subject to one or more of these tax penalties. The FTA program is one of the most under-utilized penalty…
Top 9 Most Expensive Medicaid Mistakes
…Hundreds of thousands of dollars are at stake, it is not worth the risk. 8. Failing to properly prepare for estate recovery. The estate recovery program can mean the loss…
The IRS has woken up.
…announced it will restart its global high-wealth program by commencing several hundred new examinations of high net-worth individuals between July 15, 2020 and September 30, 2020. Last month, IRS LB&I…
Streamlined Procedures for U.S. Taxpayers Residing In the United States
…the foreign financial asset; and such failures resulted from non-willful conduct. Comment: It appears that the Domestic Streamlined Program is not available to non-filers. Scope and Effect of Domestic Streamlined…
IRS Announces Key Milestone in FATCA Implementation; U.S. Begins Reciprocal Automatic Exchange of Tax Information under Intergovernmental Agreements
…facilitate this data exchange. The information now available provides the United States and partner jurisdictions an improved means of verifying the tax compliance of taxpayers using offshore banking and investment…
IRS Passport Revocation or Denial for Unpaid Taxes
…Procedures (SFCP) or Offshore Voluntary Disclosure Program (OVDP). Contact our law office to learn more. To learn more and book a free strategy session please see our dedicated website: https://www.irsrevokedpassport.com/…
ERC Disallowance Letters 105C Sent to Taxpayers
…disallowing incorrect credits before they enter the audit process. The IRS plans to send additional letters beyond the disallowance letters. It’s also finalizing plans for a special voluntary disclosure program…
Recent Webcast to DC Bar Association on Post-Election Estate Planning and Audits: Tax Considerations For the Unexpected
Parag Patel last month co-presented a Tax Law Webcast to the District of Columbia (D.C.) Bar Association on “Post-Election Estate Planning and Audits: Tax Considerations for the Unexpected”. The program…
No More Delays for FATCA: Get Ready for Disclosure
…Internal Revenue Service (IRS). FATCA, which was signed in March 2010, requires foreign banks and other financial institutions to report U.S. account holders who are evading federal taxes, or else…
Traveling? Resolve Tax Debt Before Getting Your Passport
…reverse the taxpayer’s certification within thirty days. State will then remove the certification from the taxpayer’s record, so their passport won’t be at risk under this program. The IRS can…
US FATCA Enforcement Softens due to Coronavirus
The Internal Revenue Service is giving foreign banks and financial institutions more time to file their forms about U.S. taxpayers with overseas bank accounts and other holdings in compliance with…
Maryland Retail Store Owner Guilty of Tax Fraud and Tax Evasion
…to 2018, Chawla received an annual salary from Company 1 of approximately $60,000. Each month, Chawla frequently wrote himself a $5,000 check that was drawn against Company 1’s bank account….
IRS Enforcement Campaign Targets High-Income Non-Filers
…garnishment, bank levies, or federal tax liens. Willful non-filing carries the potential for criminal prosecution. Strategic Implications This campaign signals a shift in IRS priorities, highlighting its ability to pursue…
Understanding the IRS Emphasis on BSA Filings in Tax Crime Investigations
The Internal Revenue Service (IRS) places significant emphasis on the role of Bank Secrecy Act (BSA) filings in supporting the work of its Criminal Investigations (CI) division. Their recent report…
Federal District Court Holds that FBAR Penalties in Excess of $100,000 is Unlawful
…of Foreign Bank and Financial Accounts, commonly referred to as an FBAR, could not be penalized in excess of the $100,000 regulatory maximum even though the relevant statute allows higher…
Passive Foreign Investment Company Tax & Mark-to-Market (MTM) election
…dozens of countries. However, Indian mutual funds are especially problematic because Indian dividend/capital gain treatment rules are very different, and Indian mutual funds must be linked to bank accounts, which…
Foreign Gift Received: Form 3520 Penalties Eliminated in New Court Case
…determined that the IRS could only penalize taxpayers once per-form (instead of per-account) per-year for failing to file a Report of Foreign Bank and Financial Accounts (or “FBAR”). The Wrzesinski…