Swiss Banks are Pressuring Customers to Disclose

- By : Parag Patel

…are sending letters to current or former U.S. clients warning that information about their accounts will be soon turned over to the IRS. Taxpayers who don’t step forward to the…

The questions most frequently asked about probate in New Jersey.

- By : Parag Patel

…The personal representative is required, within sixty days of probating the Will or taking out letters of administration, to notify the heirs at law, next of kin and beneficiaries in…

Start 2021 with a few New Year’s tax planning resolutions

- By : Parag Patel

…The IRS recently began mailing warning letters to certain targeted taxpayers who may have foreign accounts. Failure to report foreign accounts, or reporting them incorrectly, can have serious consequences, including…

Swiss Government and US Government Announce New Program for Cooperation and Disclosure by Swiss Banks

- By : Parag Patel

…Entities with US accounts at Swiss banks, informing them of the New Program and the OVD Initiatives. Category 3 and 4 banks seeking non-target letters Any Swiss Bank that does…

Secret Swiss Bank Accounts are No Longer Secret

- By : Parag Patel

…this backdrop that on August 29, 2013, the United States and Switzerland issued a joint statement announcing their Program for Non-Prosecution Agreements or Non-Target Letters for Swiss Banks (“Program”). In…

New FATCA Enforcement Expected

- By : Parag Patel

…the IRS about their U.S. customers or face stiff tax-withholding penalties on U.S. investments. Many Americans have received letters from their bank advising them of the bank’s FATCA participation and…

Welcome news from IRS for late Form 3520 penalties

- By : Parag Patel

…sent informational letters to taxpayers that it determined might have delinquent Form 3520 or 3520-A filing requirements (see www.irs.gov). At some point in 2019, taxpayers started to observe that late-filing Forms 3520 or 3520-A, even with…

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

- By : Parag Patel

…including examination and letters. Taxpayers who receive the letter have three options for complying. Option #1 is to make a submission under the Streamlined Filing Compliance Procedures (HERE) if they…

IRS Announces New international campaigns

- By : Parag Patel

…compliance), IRS Large Business and International Division speaking at the annual institute on current issues in International Taxation noted the IRS plans to send approximately 100 letters to US clients…

IRS Releases Training Documents on Offshore Voluntary Disclosure Program

- By : Parag Patel

…the taxpayer play an active role in the scheme? Who set up the scheme? What communications did the taxpayer initiate or become involved in- (emails, letters etc.) concerning the scheme?…

 2020 New Year’s Tax Planning Resolutions: Resolve To Plan Better

- By : Parag Patel

…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…

Penalties for Not Filing Form 3520

- By : Parag Patel

…all relevant facts and documents supporting the taxpayer’s position. If no action is taken, the taxpayer will receive one of three letters: Letter 1058, Notice of Intent of Your Right…

Resolving IRS disputes through audit reconsideration

- By : Parag Patel

…be corrected; Information that supports the taxpayer’s position, including necessary documents such as Forms 1099, canceled checks, bank statements, and loan documents; and Copies of letters and reports the IRS…

THE PROBATE PROCESS IN NJ

- By : Parag Patel

…the process, will issue letters and certificates evidencing the appointment of the individual to the Estate which will allow them to access and transfer assets such as bank accounts, stocks,…

IRS Official Provides Insights for the new IRS Streamlined Compliance Procedures

- By : Parag Patel

…at the beginning of the process have already submitted their voluntary disclosure intake letters but decide they would rather apply for relief through the streamlined compliance procedures outside of the…

IRS Listens, and Postpones Increased Form 1099 Reporting for PayPal and Venmo

- By : Parag Patel

…Office of Tax Policy, and the IRS have been receiving numerous calls and letters from the public and Congress about the Form 1099-K reporting changes. It is expected that the…

The IRS has woken up.

- By : Parag Patel

…tax non-compliance.  It is expected the non-compliance to result in more letters to taxpayers. Especially in light of anticipated tax revenue shortfalls, it is expected that the newly-awoken IRS will…

New IRS Relief for Taxpayers Experiencing COVID-related Difficulties

- By : Parag Patel

…abatement programs in the IRS. · For individual taxpayers receiving notices (letters about a tax bill) with tax liabilities up to $250,000 for Tax Year 2019 only, the IRS can…

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

- By : Parag Patel

…Bank and Financial Accounts,” if it would be sufficient to bring the individual into compliance, an IRS official said May 17. See Matthew Dalton, IRS May Issue Warning Letters on…

New York Penalty and Interest Discount (PAID) program

- By : Parag Patel

…will mail letters to taxpayers who qualify for the PAID discounts, inviting them to participate in the program. As of January 15, 2010 you’ll be able to access New York’s…