Yesterday the US Department of Justice announced here the indictment of Mark Anthony Gyetvay, who filed to enter IRS “Streamlined Filing Compliance Procedures in which he attested that his prior failure to file FBARs and tax returns
Parag Patel Esq. will be a featured speaker at a virtual New Jersey Society of Certified Public Accountants (NJCPA) Webinar panel entitled “What Tax Professionals Should Know About Trusts and Estates: Estate Tax Reform and
I am pleased to announce that I will be speaking in an upcoming Strafford live video webinar, “U.S.-India Tax Planning: Reporting Issues, Traps to Avoid, Tax Treaties, FTC, FACTA/FBAR Reporting, Passive Income” scheduled for Thursday, October 21, 1:00pm-2:30pm
The IRS is a malfunctioning mess. A recent report from the National Taxpayer Advocate, states that the IRS has failed to answer taxpayers’ requests for assistance. I have been a tax lawyer for decades and have seen
Parag Patel Esq. will be the main speaker at a virtual Broward Chapter of The Florida Society of Enrolled Agents (FSEABC) Webinar panel entitled “Upcoming federal tax law changes: What to Expect”. Mr. Patel will
The IRS quietly created new procedures for Streamlined Filing Compliance Procedures earlier this month relating to filings with “transition tax” due under Internal Revenue Code Section 965. The new procedures apply to Streamlined Domestic Offshore
Do FBAR penalties survive death? According to a new court ruling, the answer is clearly yes (unfortunately). In United States v. Gill, 2021 U.S. Dist. LEXIS 12203 (S.D. Tex. 6/30/21), the court ultimately held that
All U.S. citizens and permanent residents are required to annually file a U.S. income tax return reporting their worldwide income from all sources. Additionally, U.S. citizens and permanent who have an interest in or signatory
In the midst of tough tax season, many U.S taxpayers are unfortunately surprised to discover that they have a U.S. tax reporting obligation on financial accounts or assets held overseas. Once they discover their tax
The reporting requirements for IRS Form 5471 are complex, including ‘category of filer’ and required schedules. However, very few taxpayers know that there are special simplified filing rules for a foreign dormant corporation. Although not
The Streamlined Filing Compliance Procedure (SFCP) was “born” six years ago. Six years ago the IRS publicly announced the SFCP, which has been used by many non-compliant US taxpayers with the disclosure of foreign assets.
While a slat is commonly known as a thin, narrow strip or bar of wood or metal, a SLAT is also known to estate planning professionals as a Spousal Lifetime Access Trust (SLAT). With the
