Details of the Streamlined Domestic Offshore Procedures

- By : Parag Patel

…of laws, knowledge and violations. Although filing an SFCP does not automatically select the taxpayer for an IRS audit, the taxpayers is still subject to the possible audit selection. The…

IRS Announces Increased Enforcement on Form 5471

- By : Parag Patel

…“audit ready” file on those issues in case of an audit. Please also note that the Internal Revenue Code section 6501(c)(8) provides that the failure to file Form 5471 results…

How To Limit An Executor’s Personal Liability For A Decedent’s Unpaid Taxes

- By : Parag Patel

…invites audit and should be filed only when an audit is forthcoming or expected. To comply with Treasury Regulation § 301.6501(d)-1, the executor can complete Form 4810. Apply for Discharge…

New Jersey Transfer Inheritance Tax : How the Tax Works

- By : Parag Patel

…form must be filed with the Individual Tax Audit Branch – Inheritance and Estate Tax office in Trenton. If a husband and wife own real estate as tenants by the…

Keeping Tax Papers

- By : Parag Patel

…your tax return to complete an audit of you. That is why you want to keep records substantiating your tax return data a minimum of three years. For example, if…

IRS Official Provides Insights for the new IRS Streamlined Compliance Procedures

- By : Parag Patel

audit and criminal liability protection offered by the OVDP, according to Jennifer Best, senior adviser to the IRS deputy commissioner (International). The IRS June 18 announced it was expanding its…

FATCAts

- By : Parag Patel

…follows a similar 2009 programme, and the recently formed IRS Global High Wealth (GHW) audit unit focused on GHW compliance. Together, these enforcement mechanisms may have a significant impact on…

National Taxpayer Advocate Delivers Annual Report to Congress that Criticizes Offshore Voluntary Disclosure Programs

- By : Parag Patel

…“opt out” and be audited to obtain a lesser penalty. Uncertainty about what penalty might apply in the audit, the IRS’s one-sided interpretation of the program terms, processing delays, and…

Checklist of tax forms for taxpayers with foreign assets

- By : Parag Patel

…US tax laws, including increased criminal prosecutions and civil audit examinations. We have been advising our clients to expect the unexpected (and the worst) in their tax treatment and disclosure…

OVDI: Requesting issuance of a FBAR warning letter instead of penalties

- By : Parag Patel

…meantime, our law firm expects unabated aggressive enforcement of the US tax laws, including increased criminal prosecutions and civil audit examinations. We have been advising our clients to expect the…

IRS collects over $5 billion in its its offshore voluntary disclosure programs

- By : Parag Patel

…specific financial institution. Our law firm expects unabated aggressive enforcement of the US tax laws, including FATCA with increased criminal prosecutions and civil audit examinations. We have been advising our…

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

- By : Parag Patel

…Involuntary Discovery as a result of FATCA and Mutual Information Sharing Treaties Criminal Prosecution Lengthy comprehensive audit examination of tax returns 1-5 years’ jail sentence (based on magnitude of un-reporting)…

Streamlined Filing Compliance Procedure’s New Revisions to Streamlined Foreign Offshore Procedures (SFOP)

- By : Parag Patel

…SFCP does not automatically select the taxpayer for an IRS audit, the taxpayers is still subject to the possible normal audit selection. The taxpayer needs to be prepared to defend…

Streamlined Filing Compliance Procedure’s New Revisions to Streamlined Domestic Offshore Procedures (SDOP)

- By : Parag Patel

…does not automatically select the taxpayer for an IRS audit, the taxpayers is still subject to the possible normal audit selection. The taxpayer needs to be prepared to defend filing…

Substantially Completed Form 5471 is Required to be Filed

- By : Parag Patel

…insight as to how IRS examiners may audit a particular issue or transaction. However, they are not official pronouncements of law or directives and cannot be used, cited, or relied…

Denied access to or withdrew from the IRS Offshore Voluntary Disclosure Program (OVDP)?

- By : Parag Patel

…Accounts (FBARs). Submissions under Option #2 may result in the IRS proposing penalties and/or conducting an audit. Option #3 allows taxpayers who believe they are already fully compliant to submit…

Most Swiss banks participating in the US Department of Justice (DOJ) amnesty program seek extension to disclose

- By : Parag Patel

…obtained from banks to identify, audit, and prosecute noncompliant individuals. If the IRS identifies you noncompliance through the amnesty program you face near certain IRS scrutiny, significant liabilities, severe and…

HSBC Customer Avoids Jail in Tax Evasion Case

- By : Parag Patel

…including increased criminal prosecutions and civil audit examinations. We have been advising our clients to expect the unexpected (and the worst) in their tax treatment and disclosure of offshore assets….

IRS Official Announces New Focus on Offshore Assets in Indian Banks

- By : Parag Patel

…aggressive enforcement of the US tax laws, including increased criminal prosecutions and civil audit examinations. We have been advising our clients to expect the unexpected (and the worst) in their…

Argue for No Penalty and a Warning Letter for FBAR Violations

- By : Parag Patel

…criminal prosecutions and civil audit examinations. We have been advising our clients to expect the unexpected (and the worst) in their tax treatment and disclosure of offshore assets. Patel Law…

Streamlined Procedures for U.S. Taxpayers Residing In the United States

- By : Parag Patel

…information return penalties or FBAR penalties. Even if returns properly filed under these procedures are subsequently selected for audit, no such penalties will be imposed unless the examination results in…

FATCA Enforcement Softens

- By : Parag Patel

…or FFI that has not made a good faith effort to comply with its obligations will not be granted relief and could be subjected to an IRS audit, or other…

India Signs FATCA Model Intergovernmental Agreement to Share Account Information with the US

- By : Parag Patel

…US tax laws, including increased criminal prosecutions and civil audit examinations. We have been advising our clients to expect the unexpected (and the worst) in their tax treatment and disclosure…

Swiss Banks’ Deadline to Disclose Information is Extended

- By : Parag Patel

…to participate in the OVDP. The IRS and DOJ will continue to gather and use the information obtained from banks to identify, audit, and prosecute noncompliant individuals. If the IRS…

New Comments of the IRS’ New Streamlined Filing Compliance Procedures for Non-Resident Non-Filer U.S. Taxpayers

- By : Parag Patel

…application. – A Non-“Low Risk” Account Holders is NOT a necessarily a high risk Non-Low Risk Account Holders. “That does not mean there’s going to be an audit.” “It means…

New Report: Delinquent Taxpayers Could be Identified at US Border Crossings

- By : Parag Patel

…now that the Swiss bank non-prosecution program participation deadline of September 15, 2014 has passed. U.S. taxpayers who have been placed on the “recalcitrant” list should expect tax audit letters…

Opting Out of the Offshore Voluntary Compliance Initiative Programs

- By : Parag Patel

…for a potential audit and imposition of appropriate penalties. The 2012 OVDP program continues the procedures announced in 2011 regarding decisions to “opt out” of the voluntary disclosure penalty structure….

The IRS has woken up.

- By : Parag Patel

…as “self-dealing.” This includes making loans to disqualified individuals. IRS audits of individual tax returns showing more than $1 million of income have declined every year for the past 10…

Adding Beneficiaries to an Irrevocable Life Insurance Trust

- By : Parag Patel

…should the beneficiary predecease the grantor. However the use of contingent beneficiaries may prompt the IRS to audit and litigate. A more conservative approach is to follow the IRS rulings:…

Tax Planning Opportunities for Business Owners

- By : Parag Patel

…sales to IDITs, potentially freezing larger portions of the individual’s estate. ■ Audit previously implemented installment sales to IDITs to determine whether underlying assets are performing as originally projected (cash…