Another foreign bank customer found guilty of foreign income under-reporting and FBAR violations.

- By : Parag Patel

…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 Offices is…

Difference between Form 8938 and FBAR Requirements

- By : Parag Patel

…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 tax…

Foreign bank account reports (FBARs) and the 2011 Offshore Voluntary Disclosure Initiative (2011 OVDI)

- By : Parag Patel

…be cautious about relying on this “safe harbor” rule. If the taxpayer files the returns outside the 2011 OVDI, and, on a later audit, the IRS were to discover an…

PRESIDENT BUSH SIGNS THE HOUSING AND ECONOMIC RECOVERY ACT OF 2008 WITH TAX BENEFITS AND TRAPS FOR THE UNWARY

- By : Parag Patel

…law in place, the IRS now has the information to step in and audit the business at any time. Merchants and payment card processors have time to prepare. The new…

New Jersey Inheritance Tax

- By : Parag Patel

…real property. Form L-9 is a Real Property Tax Waiver that is filed with the Individual Tax Audit Branch – Inheritance and Estate Tax office in Trenton, New Jersey. These…

The IRS Large Business and International division (LB&I) has announced a new Loose Filed Forms 5471 compliance enforcement campaign

- By : Parag Patel

…We expect increased audit activity for clients with noncompliant Forms 5471 and foreign business activities. Patel Law Offices has consulted with hundreds of clients regarding their offshore asset and income…

President Trump Revamps the IRS through his 2019 Taxpayer First Act

- By : Parag Patel

…be a genuinely independent appellate administrative office to listen to taxpayers present their cases to the IRS. The office will work to resolve tax issues (i.e., unagreed income tax audit

Tax Strategies to Explore Now

- By : Parag Patel

…guide a client through the process and build up a defense to a possible state income tax audit. In summary, there is no time like the present to utilize these…

Automatic Form 5471 and 5472 Penalties in Spotlight by 2020 National Taxpayer Advocate Report

- By : Parag Patel

…during an audit. However, in recent years, the IRS began the systemic automatic assessment of the penalty under IRC §6038(b)(1) for late-filed Forms 5471 and 5472. As evidenced by high…

New IRS Subpoenae and IRS Data Mining Expected

- By : Parag Patel

…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 tax treatment and…

U.S. Tax Court: What to Expect

- By : Parag Patel

Reasons to Take Your Matter Before the United States Tax Court: You’ve recently undergone an audit or examination. You have taken the proper administrative steps to argue your case but…

New Jersey Division of Taxation Now Issuing Letter Rulings

- By : Parag Patel

…that the Division may contact for questions regarding the request or for redaction confirmation •Disclose any ongoing New Jersey tax matter, such as audit, refund or appeal with the Division’s…

IRS Publishes Useful Chart Outlining Compliance Options for Offshore Assets

- By : Parag Patel

…the meantime, despite the IRS’ new helpful chart, our law firm expects unabated aggressive enforcement of the US tax laws, including increased criminal prosecutions and civil audit examinations. We have…

New IRS Voluntary Disclosure in 7 Steps

- By : Parag Patel

…accordance with standard examination procedures, i.e., normal audit rules apply. Assuming taxpayer cooperation, the voluntary disclosure will be finally resolved by a closing agreement with full payment of all taxes,…

New Post-OVDP IRS Voluntary Disclosure Procedures Announced

- By : Parag Patel

…determine tax liabilities and penalties. The IRS will continue to use IRM 9.5.11.9 (no audit, no investigation, no illegal activity, etc.) to determine taxpayer eligibility for “preclearance”. After “preclearance”, taxpayers…

IRS Announces new OVDP Declines-Withdrawals Campaign

- By : Parag Patel

…those taxpayers who could not enter the program, because they are under civil audit, criminal investigation, or the IRS is otherwise aware of the account(s) at issue in the disclosure,…

Delinquent or unfiled IRS Form 5471

- By : Parag Patel

…to the risk of audit and high penalties, we strongly recommend that individuals considering becoming Form 5471 complaint and contact our law office prior to curing the noncompliance. What you…

Delinquent FinCen Form 114 (FBAR) Filings

- By : admin

…filings have caused confusion over the various IRS programs in place for individuals who need to become compliant with FBARs. Due to the risk of audit and high penalties, we…

Top myths of US tax compliance for Foreign Accountholders

- By : Parag Patel

…the IRS to audit income and assets that could otherwise remain hidden offshore. FATCA accomplishes this objective by compelling the aid of “withholding agents,” defined under FATCA as any U.S….

Tax treaty tie-breakers

- By : Parag Patel

…Center Make sure to keep a copy of the complete package, including attachments, for your records. There is an audit risk; As a result taxpayers should keep a good record….

2012 Offshore Account Criminal Tax Cases

- By : Parag Patel

…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 tax…

Top 10 factors to consider before deciding to opt out of OVDI or OVDP

- By : Parag Patel

…of returns, however if the taxpayer opts out and is audited he may be required to prepare several additional years of returns. 8. There are risks from an audit. If…

Instructions for New Streamlined Filing Compliance Procedures for Non-Resident, Non-Filer U.S. Taxpayers

- By : Parag Patel

…activity in the United States; If the taxpayer has not declared all of his/her income in his/her country of residence; If the taxpayer is under audit or investigation by the…

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

- By : Parag Patel

…and circumstances. There is simply no “one size fits all” approach. Our law firm expects unabated aggressive enforcement of the US tax laws, including increased criminal prosecutions and civil audit

New York State Bar Association Proposes OVDI Changes to IRS

- By : Parag Patel

…to opt out of the programs and undergo an audit. We agree that, given the large number of voluntary disclosures, this is an appropriate way to evaluate the culpability of…

Explore the OVDI opt-out option: Argue for Penalty Mitigation

- By : Parag Patel

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 Offices is a law…

Opting Out of the OVDI Program: Argue for No Penalty and a Warning Letter

- By : Parag Patel

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 Offices is a law…

IRS offers tax opportunity to Americans living abroad

- By : Parag Patel

…three years and delinquent FBARs for the past six years. The agency said “higher compliance risk” taxpayers would be subject to a more thorough review and, potentially, an audit. The…

Opting-out of the Offshore Voluntary Disclosure Initiative: FBAR Penalty Mitigation Guidelines

- By : Parag Patel

…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 Offices…

More Tax Complexity: New Form 8938

- 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…