Form 8938, FATCA, FBAR and penalties for all (including bankers)

- By : Parag Patel

…and will be implemented over the next 1-2 years. Our law firm expects unabated aggressive enforcement of the US tax laws, including increased criminal prosecutions and civil audit examinations. We…

Eleven foreign financial institutions to share their US customer account information

- By : Parag Patel

…accounts has increased manifold with far reaching bank investigations. The consequences for failure to comply with the proper disclosure and filing requirements may lead to audits, severe financial penalties, and…

American Citizens Abroad (ACA) writes letter to IRS Commissioner regarding unfair offshore asset treatment

- By : Parag Patel

…enforcement of the 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…

What if You Missed the OVDI Deadline?

- By : Parag Patel

…and interest determined to be due. A voluntary disclosure is generally considered to be “timely” if it is made before the government has initiated an investigation or audit of the…

For Tax Professionals: A Guide to the IRS’s Voluntary Disclosure Practice

- By : Parag Patel

…CID is not interested in pursuing a criminal investigation, the matter will be referred to IRS Exam for a civil audit. On the other hand, a “noisy disclosure” involves contacting…

How to Fix an Erroneous Filed Tax Return without Penalties

- By : Parag Patel

…examination (audit) of the tax return at issue; IRS contact with any person regarding a tax shelter examination under IRC section 6700 for a tax shelter in which the taxpayer…

The New DIIRSP: I like the old better

- By : Parag Patel

audit notices. New DIIRSP: As of November 5, 2020, the new DIIRSP is now for “taxpayers who have identified the need to file delinquent international information returns who are not…