Patel Law Offices Blog

Pre-Immigration Income Tax Planning

Since the United States has some of the highest tax rates and most complex tax rules in the world pre-immigration tax planning is very important (but rarely done). Various actions that resident and nonresident aliens take can affect the amount

Important Provisions of the American Taxpayer Relief Act of 2012

On January 1, 2013, Congress passed the American Taxpayer Relief Act of 2012 (“Act”) which was signed into law on January 2, 2013. While certain provisions of the Act are considered to be “permanent”, an overhaul of the Internal Revenue

Bank Leumi: Another Foreign Bank Recommends the IRS Voluntary Disclosure Program

Bank Leumi is urging its U.S. clients to disclose information about their accounts to U.S. authorities investigating Leumi and many other foreign banks over possible tax avoidance by Americans. In a December 16 letter Leumi urged U.S. clients to enter

Off the Cliff Commentary About the New 2013 Tax Law

As predicted, Congress waited until the last minute to make a deal, technically after we plunged off the fiscal cliff to pass a new tax law. The new 2013 tax law, in summary, is below with some of our commentary:

Uncertainty About The Future Of The Gift And Estate Tax Laws Will Continue

Even if Congress acts to avoid the “Fiscal Cliff,” uncertainty about the future of the gift and estate tax laws will continue. Despite this uncertainty, meaningful estate planning goals can be achieved. Estate planning is only partly about tax. Whatever

Benefits and consequences of entering or failing to enter the Offshore Voluntary Disclosure Initiative program

Over the past several years our law firm has counseled hundreds of non-compliant U.S. taxpayers in the exploration of their legal options with respect to the Offshore Voluntary Disclosure Initiative programs.  As a result, we have succinctly summarized some of

Tax Planning Opportunities for High Net Worth Individuals

Despite the election results, taxes are going up!  Although major tax law changes are set to take place in 2013, there are opportunities for high net worth individuals. Below are a few planning opportunities. Tax Provisions Which May Impact Planning Opportunities

Tax Planning Opportunities for Business Owners

Unless Congress acts quickly, taxes are going up!  Although major tax law changes are set to take place in 2013, there are some planning opportunities for business owners: Tax Provisions Which May Impact Planning Opportunities ■       Federal estate tax exemption decreasing

New Tax Planning Opportunities for High Income Individuals

To help appreciate the planning opportunities individuals may have between now and year end, we have prepared a summary of the key tax law provisions affecting high income individuals. Tax Provisions Which May Impact Planning Opportunities ■     Marginal ordinary income

Upcoming 2013 Tax Provisions Which Will Impact Planning Opportunities

Unless Congress acts quickly, taxes are going up!  Although major tax law changes are set to take place in 2013, uncertainty makes it hard for families and businesses alike to plan ahead. Below are the expected tax law changes: Marginal ordinary

Short Lived Planning Opportunities for the Rest of 2012

The current gift tax exclusion is scheduled to expire at midnight on December 31, 2012, bringing to an end the highest exemptions ever seen. Under current law for 2012, each person has the ability to gift or dispose of assets

To Opt Out or Not Opt Out: That is the Question

When is it appropriate to make a quiet disclosure vs. making a disclosure through the Offshore Voluntary Disclosure Program?  This question is not necessarily easy to answer. IRS agents handling OVDI/OVDP cases do not have discretion regarding offshore-related information return