Search Results for: streamlined filing compliance procedures
New FATCA / CRS reporting penalties in India
…procedures for collecting required information for almost all institutions. The information was collected on self-certification basis but no penalty was specified for submitting a false self-certification by account holders which…
Estate Planning: List of To-Do Items
…make medical decisions on your behalf and another to make financial decisions. 3. End of Life Care Consider your preferences regarding life-sustaining procedures as it relates to end-of-life care. 4….
President Trump Revamps the IRS through his 2019 Taxpayer First Act
…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…
Parag Patel to be Speaker for Estate Administration at Practicing Law Institute’s NJ Basic CLE Marathon 2021
…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…
Living Wills in New Jersey
…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…
Foreign Gift Received: Form 3520 Penalties Eliminated in New Court Case
…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…
IRS FBAR Penalties Are Now Unmitigated
…apply FBAR fines by account instead of by annual form, it is eliminating its pre-existing mitigation provisions for future non-willful violations. The IRS had regulatory procedures for reducing fines for…
Opting-out or Opting-in of OVDI
…Out and Removal Guide for the 2009 OVDP and 2011 OVDI where the procedures for opting out are set forth. The revised FAQs offer helpful guidance on the opt-out option….
New Jersey Division of Taxation Now Issuing Letter Rulings
The New Jersey Division of Taxation recently announced that it will implement new procedures for taxpayers to obtain letter rulings. Similar to letter rulings issued by the Internal Revenue Service…
Offshore Voluntary Disclosure Initiative/Program (OVDI/OVDP) opt-out results and updates
…OVDP program continues the procedures announced in 2011 regarding decisions to “opt out” of the voluntary disclosure penalty structure. In such a case, IRS agents are instructed to neither punish…
Understanding the IRS Emphasis on BSA Filings in Tax Crime Investigations
…IRS January 2024 report on the use of the BSA filings is here. The report raises important observations about the IRS’ CI investigative priorities and procedures. Key Considerations and Trends:…
Questionable ERC could mean trouble for CPAs
The Internal Revenue Service announced in March that its compliance efforts related to the Employee Retention Credit had exceeded $1 billion. The agency specified that “more than 12,000 entities filed…
Parag Patel Esq. speaks at New Jersey Society of Certified Public Accountants (NJCPA) Annual Tax Seminar: “A New Foreign Frontier: Foreign Income & Asset Reporting Update”.
…of global financial transparency and learn the requirements of foreign asset reporting. Learn best practices for compliance with foreign asset disclosure: who needs to file and assets that must be…
Checklist for for granting stock options
…required to make special filings with state securities regulators. Grant all of your stock options under the plan-If you are granting options outside the plan, special considerations will arise, which…
Republican Party Rallies Against FATCA: Success Unlikely
…be the party’s first appeal to scrap the law -the Foreign Account Tax Compliance Act (FATCA) – a panel was slated to vote at the Republican National Committee’s (RNC) winter…
IRS Announces new OVDP Declines-Withdrawals Campaign
Earlier this month, the IRS’ Large Business and International division released its list of 13 focus areas for issue- based examinations and concerns for compliance. One of those areas involves…
New voluntary disclosure program for offshore accounts in 2011
…subject to IRS inquiries, does not mean that it will not be. President Obama has targeted taxpayers with foreign accounts as lost tax revenue. The new Foreign Account Tax Compliance…
Canada and US sign FATCA tax deal where banks to share information with IRS
…signed an intergovernmental agreement (“IGA”) with the US regarding the US Foreign Account Tax Compliance Act (“FATCA”). FATCA requires U.S. financial institutions to impose a 30 percent withholding tax on…
What if You Missed the OVDI Deadline?
…the IRS has maintained a voluntary disclosure policy, under which taxpayers can disclose, and rectify, any form of tax noncompliance. To make a voluntary disclosure, a taxpayer must make a…
Another Local New Jersey client of HSBC India Pleads Guilty
…Law Offices has consulted with hundreds of clients regarding their offshore asset compliance issues. Patel Law Offices is a law firm dedicated to helping clients resolve complicated tax, criminal tax,…
More Swiss Banks Agree to Disclose US Customers Accounts: Expect More Customer Letters to be Sent
…confirmation that a lender isn’t under investigation. Our law office has consulted with dozens of clients with Swiss accounts who have received letters from their banks regarding their compliance options….
Implications of United States v. Horowitz: Reckless = Willful?
…a violation for failure to file an FBAR should contact Patel Law Offices. Over the years, our office has successfully assisted numerous taxpayers regarding their FBAR and tax compliance issues….
IRS Targets Puerto Rican Residency Transactions
…sources outside of Puerto Rico. Due to concerns regarding potential abuses of the Puerto Rico Act 2022, in January 2021, the IRS included Puerto Rico Act 2022 in its compliance…
New Webinar: An Introduction to the Taxation of Passive Foreign Investment Companies
…emphasis on investments in foreign mutual funds and foreign hedge funds Important elections to consider when making investments in PFICs Practical solutions to address non-compliance or missed elections in this…
New Law’s Reporting Requirements Make It Very Likely That the IRS Will Now Know About Your Foreign Account
Under the recently enacted Foreign Account Tax Compliance Act (“FATCA”), foreign financial institutions (“Financial institutions” is broadly defined to include banks, mutual funds, funds of funds, exchange-traded funds, hedge funds,…
Watch Out: Malta Pension Plans Become Listed Transaction
…the IRS will take the position that taxpayers are not entitled to the purported tax benefits. A tax attorney with experience in the Malta plans can assist taxpayers in compliance….
IRS Official Announces New Focus on Offshore Assets in Indian Banks
…tax treatment and disclosure of offshore assets, particularly for Indian assets. Patel Law Offices has consulted with hundreds of clients regarding their offshore asset compliance issues. Patel Law Offices is…
HSBC Customer Avoids Jail in Tax Evasion Case
…Patel Law Offices has consulted with hundreds of clients regarding their offshore compliance issues. Patel Law Offices is a law firm dedicated to helping clients resolve complicated tax, criminal tax,…
IRS collects over $5 billion in its its offshore voluntary disclosure programs
…third program it opened in January this year. “We continue to make strong progress in our international compliance efforts that help ensure honest taxpayers are not footing the bill for…
Internal Revenue Service announces new International Data Exchange Service: The Beginning of Information Sharing
…send their information reports on financial accounts held by U.S. persons to the IRS under the Foreign Account Tax Compliance Act (FATCA) or pursuant to the terms of an intergovernmental…