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…

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 Comments of the IRS’ New Streamlined Filing Compliance Procedures for Non-Resident Non-Filer U.S. Taxpayers

- By : Parag Patel

…Non-Resident U.S. Taxpayers seems to be a new EZPASS or express OVDP without any penalties. We are comprehensively exploring this alternative for our clients and expect to aggressively advocate for…

Top FBAR Reporting Error

- By : Parag Patel

…who fail to resolve prior reporting errors can expect harsh treatment from U.S. tax authorities and remain exposed to substantial penalties and possible criminal prosecution. Similarly, U.S. courts have not…

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…