Search Results for: streamlined filing compliance procedures
U.S. Signs FATCA Pacts with Malta, Netherlands, Bermuda, Jersey, Guernsey and Isle of Man
Last week, the U.S. signed six more intergovernmental agreements with a half dozen jurisdictions, including several traditional offshore tax havens, to implement the Foreign Account Tax Compliance Act, or FATCA….
The New IRS ERC Voluntary Disclosure Program
…notice and demand to repay part or all of the ERC. The IRS has not received information from a third party that the taxpayer is not in compliance or has…
FATCA Deadlines Extended
…a notice extending the time under which certain transitional rules for the Foreign Account Tax Compliance Act will apply. FATCA was included as part of the HIRE Act of 2010…
No Springing in Spring
…you when you need it. Compliance Issues. A bank might not accept the agent’s authority without confirmation that the signatures of the physicians are genuine and some reassurance that the…
2020 New Year’s Tax Planning Resolutions: Resolve To Plan Better
…foreign accounts. The IRS has publicly stated that foreign accounts tax compliance is a priority in enforcement. In 2019, the IRS announced that it began mailing warning letters to certain…
India Signs FATCA Model Intergovernmental Agreement to Share Account Information with the US
…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 a law firm dedicated…
Parag Patel Esq. Speaks at NJCPA Seminar on”Criminal Tax: What Tax Professionals Need to Know to Help Clients and Themselves”
…of taxpayers to report virtual currency. This session will provide an overview of recent IRS fraud compliance efforts and how to handle and assist clients with potential civil and criminal…
Rare confluence of tax law and immigration law
…separately prosecuted in most instances. The case presents new risks for Greencard holders who wish to become citizens. Such individuals should carefully review their US tax compliance of foreign accounts…
FATCA-Compliant Institutions List Goes Online
While over 77,000 banks and financial institutions have registered under FATCA—the Foreign Account Tax Compliance Act, the Internal Revenue Service has introduced an online tool that will allow users to…
Deficient Nursing Homes Listed
…facilities were periodically instituting enough improvement so that they would pass one survey, only to fail the next for many of the same problems as before. Facilities with this compliance…
FATCA Noncompliant Accounts may be Frozen or Blocked
…be permanently blocked until compliant. Compliance has its own costs and obligations. Under the FATCA law, financial and account information regarding an account owned by a US customer would be…
Caution: Foreign Businesses Require Additional Reporting
…may find that their U.S. connection brings unwanted U.S. reporting requirements and scrutiny. Aside from the CFC rules discussed above, the new FATCA (Foreign Account Tax Compliance Act) requires ownership…
“Beneficial Owner” Analysis under the new Corporate Transparency Act
Starting January 1, 2024, the Corporate Transparency Act (CTA) will require most U.S. corporations, LLCs, and other legal entities formed through state filings or foreign entities registered to do business…
US passport and green-card has lost its glamour
A US passport or green-card is losing its glamour and appeal. Some people are surrendering their prized green cards because of the US Foreign Account Tax Compliance Act (FATCA), which…
National Taxpayer Advocate Criticizes IRS over handling of offshore voluntary disclosures
The 2012 National Taxpayer Advocate (NTA) Annual Report to Congress criticized current IRS practices in the Offshore Voluntary Disclosure Program (OVDP) that hinder voluntary compliance by penalizing taxpayers who are…
The IRS publishes new proposed regulations for tax on transfers from covered expatriates
…compliance for each of the past five years. (Exceptions exist for certain dual citizens at birth and certain minors.) Tax on gifts and bequests from covered expatriates Before the enactment…
Expect new aggressive IRS targeted enforcement next year.
…identify and warn targeted taxpayers of certain problems with their returns to increase voluntary tax compliance via IRS voluntary disclosure programs. As a result, we anticipate increased enforcement next year…
The Taxpaper Roadmap (seriously?)
…you can see from the map’s numerous twists and turns, the road to IRS compliance is not easy to navigate, even for a tax lawyer. The colorful map looks more…
Foreign Gifts and the Uncommon Form 3520: A Trap for the Unwary
…regarding their Form 3520 compliance issues. Patel Law Offices offers a free strategy session to discuss how to resolve your foreign asset problem. Conveniently schedule online today by completing our questionnaire…
Unfiled FBAR Penalties Survive Death
…FBARs must be filed to avoid possible penalties in the future (and after death). Furthermore, estate executors must vigilantly review FBAR filing obligations of the decedent to see if any…
Forms 3520, 5471 and 5472 Penalty Relief
…only administrative recourse for taxpayers with reasonable cause for their late filing is submitting a written abatement request to the service center that issued the notice. Some recent anecdotal evidence…
NJ Tax Waiver Shortcut
…filing a Form L-8 or L-9. Because spouses, civil union partners, children, stepchildren, grandchildren and parents of the deceased are exempt from the New Jersey Inheritance Tax, often no Inheritance…
30-DAY LETTERS VS. 90-DAY LETTERS IN TAX AUDITS
…for time needed to process the case filing from the date of closing to review and closing by the Group Manager; -the nature of the issues and the complexity of…
New Jersey Enacts Tax Amnesty Bill
…late filing penalties; – cost of collection; – delinquency penalties; or – recovery fees. However, a taxpayer is required to pay any civil fraud or criminal penalties arising out of…
US Supreme Court to Rule on FBAR Penalties Case
…penalties for the same conduct in different parts of the country. It is hoped that the Supreme Court rules in favor of a per filing and not per account basis….
Post-Covid: Re-explore the Home Office deduction
…use. Self-employed taxpayers filing IRS Schedule C, Profit or Loss from Business (Sole Proprietorship) first figure this deduction on Form 8829, Expenses for Business Use of Your Home. The IRS introduced a Simplified…
Financial Crimes Enforcement Network (FINCEN) Issue Final Rules
…may be to these requirements. Despite the fact that the instructions to the FBAR make such specifications, there was still much confusion over the filing requirements. In an effort to…
HSBC Expected to Disclose Account Holders Names
…to report income earned on those undisclosed accounts.” US law requires such account holders to annually declare any offshore account that contains at least $10,000 in a special filing. In…
Permanent annual automatic extensions granted for FBARs to October 15
…of April 15 (April 18 for 2017), it will automatically grant all taxpayers filing the form a six-month extension every year to Oct. 15 (which will be Oct. 16, 2017,…
Another U.S. taxpayer with an offshore HSBC bank account pleads guilty
On April 13, 2011, another U.S. taxpayer with an offshore HSBC bank account, Josephine Bhasin (United States v. Bhasin, E.D.N.Y., No. 11-cr-00268-ADS), pled guilty to charges of knowingly filing false…