Form 3520 Penalty Relief
We have recently posted about the IRS’s broad relief for late filing penalties for 2019 and 2020 tax returns. During the height of the pandemic, taxpayers experienced many obstacles to the timely filing of their
Two-day educational event focused on Trusts and Estate taxation
Parag Patel Esq. was a featured speaker at the National Association of Enrolled Agents (NAEA) LEARN event in Pittsburgh, PA from September 25–27, 2022. The two-day educational event focused on Trusts and Estate taxation. Mr.
Recent Court Decision Shows Risks of IRS Streamlined Filing Compliance Procedures
A recent court decision from the United States Court of Federal Claims shows the impact of a poorly advised Streamlined Filing Compliance Procedures (Streamlined Program or SFCP) submission. See Flint v. U.S., No. 21-1202T (Fed.
Forms 3520, 5471 and 5472 Penalty Relief
In IRS Notice 2022-36, the IRS granted relief from certain failure-to-file penalties and certain international information return penalties for most individual and business taxpayers who did not file tax returns for tax years 2019 and 2020,
IRS gives widespread penalty relief: ACTION REQUIRED
Last week, in IRS Notice 2022-36, the IRS granted relief from certain failure-to-file penalties and certain international information return penalties for most individual and business taxpayers who did not file tax returns for tax years 2019
Foreign pension accounts reporting on the FBAR
Several clients have asked us in recent weeks whether foreign pension accounts are reported on the FinCen114 (FBAR). Most employer foreign pension plans fall under one of two types: defined benefit plan or defined contribution
US Reporting of Foreign Retirement Accounts
Many clients contact our office regarding the failure to report their foreign retirement account. Such accounts need to be fully reported on an FinCen 114 (FBAR) and IRS Form 8938. Besides the need to disclose
Is the IRS Finally Receiving Increased Funding?
After months of back and forth, it appears that additional funding is on its way to the Internal Revenue Service (IRS) with the Inflation Reduction Act of 2022 (Act). The Act would spend nearly $80
IRS Extends Late Portability Election Automatic Relief from 2 to 5 Years
On July, 8, 2022, the Internal Revenue Service released Revenue Procedure 2022-32, which provides a simplified method for certain estates to make a late portability election to allow the surviving spouse of the decedent to
IRS Summons to a Third Party: Duties and Rights
One of the most common evidence-gathering tactics used by the Criminal Investigative Division is the issuance of summonses. The IRS has very broad discretion to use summonses, which are authorized by statute to allow special
Maryland Retail Store Owner Guilty of Tax Fraud and Tax Evasion
Sunil Chawla (“Chawla”), age 66, of Berlin, Maryland, pleaded guilty this week to tax fraud. As part of his plea agreement, Chawla will be required to pay $70,000 in restitution. According to his guilty plea,
Specific Steps for Applying to the IRS Streamlined Foreign Offshore Procedures
If you are a US Person and not compliant for not properly reporting foreign accounts, assets, investments, and income to the IRS, you may have learned about Streamlined Procedures. If you live outside the US