Citizenship renunciation fee increases as American expatriates flee FATCA

- By : Parag Patel

…retaining the right of residence in the USA. Our firm presented an informational webinar on the new Streamlined Filing Compliance Procedures available to many expats. Materials from the webinar can…

The New DIIRSP: I like the old better

- By : Parag Patel

…the taxpayer has not failed to report tax.  Old DIIRSP: Before the change, the DIIRSP originally stated: Taxpayers who do not need to use the OVDP or the Streamlined Filing…

2 recent IRS developments that will impact Indian Americans

- By : Parag Patel

…application show less than $1,500 in tax due in each of the years, they will be treated as low risk and processed in a streamlined manner. The risk level may…

IRS announces an update to its Voluntary Disclosure Practice Preclearance Request and Application

- By : Parag Patel

…Criminal Investigation Voluntary Disclosure Practice IRM 9.5.11, Investigative Process – Other Investigations IRM 4.63.3, Withholding and International Individual Compliance – Offshore Voluntary Disclosure Program, Streamlined Filing Compliance Procedures and Voluntary…

Beware of FATCA Letters

- By : Parag Patel

…FBAR by US taxpayers with extensive foreign assets. Both should already have been filed for previous financial years. You should also discuss the Streamlined Filing Procedure with your tax professional….

Cost of Compliance Rises under OVDP

- By : Parag Patel

…amnesty even for willful acts. But for those with the right facts, the IRS Streamlined program is simpler and less costly. US taxpayers considering an OVDP disclosure need to take…

Analysis: IRS New Disclosure Program

- By : Parag Patel

…Correction Procedures Remain Unaffected The memorandum importantly states that the IRS’ Streamlined Filing Compliance Procedures, the Delinquent FBAR submission procedures, and the Delinquent International Information Return submission procedures are still…

2011 Offshore Voluntary Disclosure Initiative Frequently Asked Questions (FAQs) and Answers

- By : Parag Patel

We have reviewed the new 2011 OVDI FAQs and noticed that the Service has refined and streamlined the voluntary disclosure process. Our firm prepared dozens of voluntary disclosure applications in…

IRS expands use of Subpeonas

- By : Parag Patel

…of information, and when you couple that with what we have received from the offshore compliance initiative and the streamlined filing program, we have actually been able to secure quite…

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…

Watch Out for Letters From Your Foreign Bank Requesting Information On Your U.S. Residency

- By : Parag Patel

…large penalty or face criminal prosecution. We often recommend that U.S. taxpayers with undisclosed overseas accounts enter into the IRS’s new Streamlined Program (SDOP or SFOP) or Offshore Voluntary Disclosure…

IRS Passport Revocation or Denial for Unpaid Taxes

- By : Parag Patel

…financial accounts. Now is the time to become tax compliant, there are various options to achieve this. You may want to participate in the IRS’ Streamlined Filing Compliance Procedures (SFCP)…

National Taxpayer Advocate Identifies OVDP Program as a Serious Problem

- By : Parag Patel

…a few situations in which a taxpayer could opt out without penalty. In addition, on September 1, 2012, it established a Streamlined Nonresident Filing Initiative that allows certain nonresidents to…

IRS delinquent FBAR submission procedure

- By : Parag Patel

…counsel in filing the delinquent FBAR submission procedure. Delinquent FBAR Submission Procedures Taxpayers who do not need to use either the OVDP or the Streamlined Filing Compliance Procedures to file…

New IRS Relief for Taxpayers Experiencing COVID-related Difficulties

- By : Parag Patel

…easing paperwork requirements to allow individuals more flexibility to get non-streamlined Installment Agreements up to $250,000 without financial verification, if their case is not yet assigned to a revenue officer….

New EZPASS OVDP Without Any Penalties for Non-Resident U.S. Taxpayers

- By : Parag Patel

…8891 regarding retirement or savings plans by treaty. Also, once a taxpayer attempts this new streamlined program, the OVDP is no longer available. Even worse, there appears to be no…

IRS Announces Penalty Mitigation for Smaller US Taxpayers Living Abroad

- By : Parag Patel

…is made on a timely basis. The streamlined procedures will be made available to resolve low compliance risk situations even though this election was not made on a timely basis….

The New IRS Voluntary Disclosure Practice: Not a Good Deal for Noncompliant Taxpayers

- By : Parag Patel

…Office of Appeals. The VDP does not impact the existence of the IRS’ Streamlined filing compliance procedures. The Advantages and Disadvantages of the IRS New Voluntary Disclosure Practice: Advantages: Avoidance…

US Court finds non-willful FBAR penalty not limited to $10,000 per year

- By : Parag Patel

…ruling, taxpayers with unreported foreign financial accounts should consider entering one of the IRS’ voluntary disclosure programs, such as the Streamlined Domestic Offshore Procedure. Noncompliant taxpayers are strongly recommended to…