Post IRS Audit Strategic Options: The IRS’ 30 Day Letter

- By : Parag Patel

If, after conducting the audit, a taxpayer and revenue agent cannot come to an agreement, the agent will prepare and submit to the taxpayer a preliminary notice of deficiency, or…

To Gift or Not to Gift? Gift.

- By : Parag Patel

tax benefits.  We are advising clients of the likely impact of an electoral victory in November for Joe Biden. Biden’s recently published tax plan calls for increases in estate taxes….

The IRS can revoke your passport

- By : Parag Patel

taxpayer representatives, even if they have a valid power of attorney on file that includes all of the tax years that comprise the seriously delinquent tax debt. The Taxpayer Advocate…

IRS Updated Voluntary Disclosure Practice is a Game-Changer

- By : Parag Patel

…will assess a civil-fraud penalty to the tax year during the disclosure period with the highest tax liability. In exceptional cases, taxpayers can request the imposition of the lower 20%…

The IRS Needs Help

- By : Parag Patel

…millions of people who cannot afford a tax lawyer to get help. Tax lawyers often have access to tax practitioner hotlines to get quicker resolution of issues. The rest of…

The Strange Case of U.S. v. Hughes: Willful and Non-Willful (at the Same Time?)

- By : Parag Patel

…that the taxpayer was non-willful between 2010-2011 because there was no clear evidence that the taxpayer had looked over any Schedule B when submitting the tax return. This means that…

If you are a landlord, what changes need to be made to assure that you can be considered to be an active trade or business to qualify for the Section 199A deduction if you have net income from the rentals?

- By : Parag Patel

Internal Revenue Code Section 199A was enacted as part of the 2017 Tax Cuts and Jobs Act (TCJA), and slightly modified in 2018. This provision provides a tax deduction of…

Recent Court Decision Shows Risks of IRS Streamlined Filing Compliance Procedures

- By : Parag Patel

…IRS may reject the taxpayer’s Streamlined submission. And worse, if the taxpayer provides false or fraudulent information in the narrative statement, the taxpayer could potentially face criminal prosecution. In the…

Two-day educational event focused on Trusts and Estate taxation

- By : Parag Patel

…avoid. The National Association of Enrolled Agents (NAEA) is the nation’s leading association community for tax practitioners. NAEA’s members are the tax practitioners involved in tax preparation and tax representation. …

IRS Updates Process for FAQs

- By : Parag Patel

…(1) “should never assess a penalty against a taxpayer for taking a position consistent with an FAQ posted on the IRS website at the end of a taxpayer’s taxable year…

New Form Updates for Foreign Accounts

- By : Parag Patel

…partnership’s gross income for the taxable year is passive income or at least 50 percent of the assets held by the corporation or partnership for the taxable year are assets…

Estate Planning and Life Insurance Trusts

- By : Parag Patel

…own a life insurance policy with a substantial death benefit. This is because life insurance proceeds, while not subject to federal income tax, are considered part of your taxable estate…

New IRS FBAR Practice Unit

- By : Parag Patel

…IRS (and its agents) interpret these rules. To help taxpayers and tax advisors, this article provides a summary of the FBAR Practice Unit. General: The Bank Secrecy Act (“BSA”) requires…

FBAR Deadline Automatic Extension

- By : Parag Patel

…account disclosures that must now be made on a taxpayer’s annual income U.S. income tax return (e.g. Form 1040, Schedule B; and Form 8938 -“FATCA” disclosure). Beginning for the 2016…

Stretching Your IRA to the Next Generation

- By : Parag Patel

tax consequences. They cannot simply roll it into their own IRA without tax implications. “Look-through trust options” add additional flexibility and control for stretch IRAs. There are two effective trust…

FATCA Noncompliant Accounts may be Frozen or Blocked

- By : Parag Patel

…shared with the IRS. If the US account holder has not properly reported the existence of the account and income earned on the account on US tax returns then significant…

Swiss Banks’ Deadline to Disclose Information is Extended

- By : Parag Patel

…evade taxes to turn over information by one month. We have previously posted on the U.S. Justice Department’s program offered to Swiss banks and targeted to identifying U.S. taxpayers that…

New guidance on fixing a botched IRA stretch after it’s “too late”

- By : Parag Patel

…higher marginal tax rates) on several years of RMDs lumped into a single year, the beneficiary must still pay the whopping 50% excise tax on the amounts that were not…

The Secret Stretch IRA

- By : Parag Patel

…withdrawals over his remaining life expectancy. He has to pay income taxes only on the amount he withdraws every year. That’s a huge tax benefit considering that if the father…

Accountant-Client vs Attorney-Client Confidentiality

- By : Parag Patel

…practice before the IRS. Furthermore, the confidentiality does not apply to criminal proceedings, documents needed to prepare a tax return, or communications regarding tax shelters. For example, if you are…

National Taxpayer Advocate calls IRS Penalties Draconian and Inefficient

- By : Parag Patel

…or inaccurate. Although Congress intended these requirements to prevent wealthy taxpayers and corporations from hiding income and assets abroad, the international information return (IIR) regime also harms unsuspecting lowerincome taxpayers,…

Another Foreign Bank Charged by U.S. Department of Justice

- By : Parag Patel

…presence in the U.S. Patel Law Offices is a law firm dedicated to helping clients resolve complicated tax, criminal tax, and international tax problems. Our firm assists (and defends) clients…

“Willfulness” When Deciding Whether to Opt Out of 2011 OVDI

- By : Parag Patel

…Offices is a law firm dedicated to helping clients resolve complicated tax, criminal tax, and international tax problems. Our firm assists (and defends) clients and their advisors to legally disclose…

In Addition to HSBC, Credit Suisse Also Being Investigated for Offshore Activities

- By : Parag Patel

…is a law firm dedicated to helping clients resolve complicated tax, criminal tax, and international tax problems. Our firm assists (and defends) clients and their advisors to legally disclose (and…

Foreign Account Penalties Are Unfair

- By : Parag Patel

…be subject to large unfair penalties. Patel Law Offices is a law firm dedicated to helping clients resolve complicated tax, criminal tax, and international tax problems. Our firm assists (and…

Opting Out of the Offshore Voluntary Compliance Initiative Programs

- By : Parag Patel

…of clients regarding offshore voluntary compliance issues. Patel Law Offices is a law firm dedicated to helping clients resolve complicated tax, criminal tax, and international tax problems. Our firm assists…

Financial Crimes Enforcement Network (FINCEN) Issue Final Rules

- By : Parag Patel

…firm dedicated to helping clients resolve complicated tax, criminal tax, and international tax problems. Our firm assists (and defends) clients and their advisors to legally disclose (and legitimize) foreign accounts….

New Law’s Reporting Requirements Make It Very Likely That the IRS Will Now Know About Your Foreign Account

- By : Parag Patel

…Voluntary Disclosure Initiative (2011 OVDI) program and avoid criminal prosecution. Patel Law Offices is a law firm dedicated to helping clients resolve complicated tax, criminal tax, and international tax problems….

Offshore Voluntary Disclosure Initiative/Program (OVDI/OVDP) opt-out results and updates

- By : Parag Patel

…dedicated to helping clients resolve complicated tax, criminal tax, and international tax problems. Our firm assists (and defends) clients and their advisors to legally disclose (and legitimize) foreign accounts. For…

New Taxpayer Advocate Service Report Discusses Optouts out of the OVDI/OVDP

- By : Parag Patel

…firm dedicated to helping clients resolve complicated tax, criminal tax, and international tax problems. Our firm assists (and defends) clients and their advisors to legally disclose (and legitimize) foreign accounts….