The IRS is aggressively targeting conservation easements, calling them abusive tax shelters and pursuing audits, penalties, and even criminal charges. Taxpayers who claimed deductions could face full disallowance, massive fraud penalties, and potential prosecution. Promoters,
The John Doe summons remains one of the IRS’s most formidable tools for uncovering tax noncompliance among individuals who seek to evade U.S. tax obligations through offshore activities. Unlike a standard summons, the John Doe
Parag Patel Esq. is a featured speaker at the National Association of Enrolled Agents (NAEA) Seminar entitled “Criminal Tax: What Tax Professionals Need to Know to Help Clients and Themselves” on January 23, 2025. Seminar
Parag Patel Esq. was a featured speaker at a New Jersey Society of Certified Public Accountants (NJCPA) Seminar for Essex County entitled “Federal Tax Update: What to Expect for the Unexpecting: What Tax Professionals Need
The John Doe summons is a powerful investigative tool employed by the IRS to uncover the identities of taxpayers suspected of noncompliance with federal tax laws. Unlike traditional summonses, this device targets individuals or classes
The IRS Criminal Voluntary Disclosure Practice (VDP) has long served as an important tool for taxpayers with potential criminal exposure to rectify their noncompliance and meet their tax obligations. However, recent modifications to the program’s
Parag Patel Esq. was a featured speaker at a New Jersey Society of Certified Public Accountants (NJCPA) Seminar entitled “ A New Foreign Frontier: Foreign Income & Asset Reporting Update ” on November 23, 2024.
I am pleased to announce that I will be speaking in an upcoming Strafford live video webinar, U.S.-India Tax Planning: Key Issues, Tax Treaties on Monday, December 16, from 1:00pm-2:30pm EST. Our panel will provide tax counsel
Understanding the Section 83(b) Election Employees who receive restricted stock or other property for their services often face a complex tax situation. Typically, income tax is due when the stock vests, meaning when the employee
In the case of Mukhi v. Commissioner (163 T.C. No. 8, November 18, 2024), the U.S. Tax Court ruled that the IRS lacks the authority under Code Section 6038(b)(1) to impose an assessment for failure
Parag Patel Esq. was a featured speaker at a New Jersey Society of Certified Public Accountants (NJCPA) Seminar entitled “Federal Tax Enforcement Update:What to Expect for the Unexpecting: What Tax Professionals Need to Know to
The IRS’s updates to Form 14457, “Voluntary Disclosure Practice Preclearance and Application,” mark a significant tightening of the program’s requirements and an intensification of its focus on enforcement. These changes, including a new willfulness admission,
