Search Results for: audit
American Citizens Abroad (ACA) writes letter to IRS Commissioner regarding unfair offshore asset treatment
…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…
President Trump Revamps the IRS through his 2019 Taxpayer First Act
…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…
Parag Patel Esq. speaks at NJCPA Seminar ” Federal Tax Update and Latest Tax Controversy Hot Topics”
…with the latest developments in tax controversy. This session will explore tax collection developments, penalty developments, new voluntary disclosure programs, the latest IRS audit campaign initiatives and other hot topics…
IRS Provides Form 5471 Information-Filing Relief For Dormant Foreign Corps.
…or 4.04, within 90 days of being asked to do so on audit. SEC. 5. RELIEF 01 Persons complying with the summary filing procedure described in section 4 satisfy their…
Eleven foreign financial institutions to share their US customer account information
…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…
Parag Patel Esq. speaks at New Jersey Society of Certified Public Accountants (NJCPA) Annual Tax Seminar: “2022 Federal Tax Update and Latest Tax Controversy Hot Topics”.
…tax controversy. We will explore tax collection developments, penalty developments, new voluntary disclosure programs, the latest IRS audit campaign initiatives, and other hot topics in tax controversy. The New Jersey…
Form 8938, FATCA, FBAR and penalties for all (including bankers)
…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…
More Tax Complexity: New Form 8938
…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…
Most Swiss banks participating in the US Department of Justice (DOJ) amnesty program seek extension to disclose
…obtained from banks to identify, audit, and prosecute noncompliant individuals. If the IRS identifies you noncompliance through the amnesty program you face near certain IRS scrutiny, significant liabilities, severe and…
Opting-out of the Offshore Voluntary Disclosure Initiative: FBAR Penalty Mitigation Guidelines
…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…
FATCA Enforcement Softens
…or FFI that has not made a good faith effort to comply with its obligations will not be granted relief and could be subjected to an IRS audit, or other…
IRS offers tax opportunity to Americans living abroad
…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…
The New DIIRSP: I like the old better
…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…
India Signs FATCA Model Intergovernmental Agreement to Share Account Information with the US
…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 disclosure…
Opting Out of the OVDI Program: Argue for No Penalty and a Warning Letter
…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…
Explore the OVDI opt-out option: Argue for Penalty Mitigation
…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…
To Opt Out or Not Opt Out: That is the Question
…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 Comments of the IRS’ New Streamlined Filing Compliance Procedures for Non-Resident Non-Filer U.S. Taxpayers
…application. – A Non-“Low Risk” Account Holders is NOT a necessarily a high risk Non-Low Risk Account Holders. “That does not mean there’s going to be an audit.” “It means…
The Unknown Tax: New Jersey Inheritance Tax
…Audit Branch – Inheritance and Estate Tax office in Trenton, New Jersey. These forms can be downloaded from the State of New Jersey Treasury website at www.state.nj.us/treasury/taxation. When a husband…
IRS Publishes Useful Chart Outlining Compliance Options for Offshore Assets
…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…
Instructions for New Streamlined Filing Compliance Procedures for Non-Resident, Non-Filer U.S. Taxpayers
…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…
Swiss Banks’ Deadline to Disclose Information is Extended
…to participate in the OVDP. The IRS and DOJ will continue to gather and use the information obtained from banks to identify, audit, and prosecute noncompliant individuals. If the IRS…
Top 10 factors to consider before deciding to opt out of OVDI or OVDP
…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…
2012 Offshore Account Criminal Tax Cases
…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 disclosure of…
Tax Planning Opportunities for Business Owners
…sales to IDITs, potentially freezing larger portions of the individual’s estate. ■ Audit previously implemented installment sales to IDITs to determine whether underlying assets are performing as originally projected (cash…
Tax treaty tie-breakers
…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….
Adding Beneficiaries to an Irrevocable Life Insurance Trust
…should the beneficiary predecease the grantor. However the use of contingent beneficiaries may prompt the IRS to audit and litigate. A more conservative approach is to follow the IRS rulings:…
The IRS Large Business and International division (LB&I) has announced a new Loose Filed Forms 5471 compliance enforcement campaign
…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…
How to Fix an Erroneous Filed Tax Return without Penalties
…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…
How Long is the Tax Fraud Statute of Limitations?
…indefinite or unlimited fraud statute refers to civil tax fraud, not criminal tax matters. The IRS basically has unlimited time to audit you for civil fraud. But due to the…