How To Limit An Executor’s Personal Liability For A Decedent’s Unpaid Taxes

- By : Parag Patel

…the IRS can still assess deficiencies against the estate or its beneficiaries, heirs, and transferees. File Notice of Termination of Fiduciary Relationship (IRS Form 56) An executor can shield herself…

IRS Publicizes and Celebrates OVDI Success

- By : Parag Patel

…“have provided the IRS with a wealth of information on various banks and advisors assisting people with offshore tax evasion, and the IRS will use this information to continue its…

IRS Aggressively Starts New Criminal Investigations

- By : Parag Patel

…taken up by the Criminal Investigation division. The IRS is also escalating enforcement efforts around unlawful offshore tactics, specifically targeting Maltese personal pension plan schemes. In June, the IRS and…

Details of the Streamlined Foreign Offshore Procedures (SFOP)

- By : Parag Patel

…(SDOP) or the Streamlined Foreign Offshore Procedures (SFOP). This article focuses on the SFOP. The Internal Revenue Service (IRS) recently modified the non-willfulness certification form that individual taxpayers must submit…

Another Bank Discloses Accountholders: Credit Suisse to Turn Over U.S. Account Data

- By : Parag Patel

appeal, according to the letter. Taxpayers can consent to the SFTA handing over their account data to the IRS, or they can use the Swiss legal system to appeal a…

15 IRS Audit Tips

- By : Parag Patel

…adjustments in these years too. 7. The IRS must complete an audit within three years of the time the tax return is filed, unless the IRS finds tax fraud or…

Opt Out of OVDI Program Penalties to Get a Lower Penalty

- By : Parag Patel

…the IRS. In such a case, IRS agents are instructed to neither punish nor reward persons who choose to opt out. Once an irrevocable opt out decision is made, our…

IRS Audits of Millionaires Remain Very Low

- By : Parag Patel

…shows that low-income earners were more than five times more likely to be targeted by the IRS in 2022. TRAC, a nonpartisan data gathering and distribution organization, was able to…

The Dreaded IRS Letter 6185: “We received information that you have a foreign account”

- By : Parag Patel

IRS amnesty programs and making payment for applicable taxes, interest, and penalties. HOW TO RESPOND: If you received IRS Letter 6185, take it very seriously. Do not ignore the letter….

Beware IRS Letter 6291

- By : Parag Patel

…Via FATCA and subpoenaed bank records, the IRS is in possession of records that identify taxpayers with transactions or accounts at offshore private banks. Soft letters are IRS correspondence to…

IRS Announces Major New changes to the Offshore Voluntary Disclosure Program

- By : Parag Patel

The IRS today made significant changes to its offshore voluntary compliance programs, with the intent of providing new options to help both taxpayers residing overseas and those residing in the…

The IRS Large Business and International division (LB&I) has announced a new Offshore Private Banking enforcement campaign

- By : Parag Patel

The new Offshore Private Banking enforcement campaign was recently identified through LB&I data analysis and suggestions from IRS employees. IRS employees likely saw that many taxpayers were not properly reporting…

New Comments of the IRS’ New Streamlined Filing Compliance Procedures for Non-Resident Non-Filer U.S. Taxpayers

- By : Parag Patel

…Streamlined Filing Compliance Procedures for Non-Resident, Non-Filer U.S. Taxpayers (see IRS Instructions here). David Horton, a senior official from the IRS, made some interesting statements about Non-Low Risk Account Holders…

IRS delinquent FBAR submission procedure

- By : Parag Patel

Last spring, the IRS revised its program for delinquent FBAR returns. The IRS offers a new “delinquent FBAR submission procedure”. See below excerpt from the IRS website.The program is available…

Denied access to or withdrew from the IRS Offshore Voluntary Disclosure Program (OVDP)?

- By : Parag Patel

This year taxpayers who either were denied access to or withdrew from the IRS Offshore Voluntary Disclosure Program (OVDP) have been receiving Letter 5935 (HERE) from the IRS notifying them…

IRS Announces New international campaigns

- By : Parag Patel

…compliance), IRS Large Business and International Division speaking at the annual institute on current issues in International Taxation noted the IRS plans to send approximately 100 letters to US clients…

FATCA Enforcement Softens

- By : Parag Patel

Realizing the large administrative burden of FATCA, the IRS has announced a “soft opening” of FATCA and enforcement at the IRS’ discretion for an initial transitional period. FATCA, which was…

IRS expands use of Subpeonas

- By : Parag Patel

…John Doe summonses were a breakthrough for the IRS in tackling offshore tax evasion when they were first addressed to banks to divulge the identity of U.S. customers suspected of…

Foreign Account Tax Compliance Act (FATCA) online registration program is launched

- By : Parag Patel

IRS will start collecting customer account information from foreign institutions in 2015. In the meantime, though, the IRS has launched an online registration program for financial firms around the world…

How to Avoid Employee Retention Credit (ERC) Scams

- By : Parag Patel

…supply of critical goods or materials that caused the inability of the employer to operate. Issues Raised on IRS Audit The IRS will be aggressively auditing ERC refund claims. Employers…

IRS gives widespread penalty relief: ACTION REQUIRED

- By : Parag Patel

Last week, in IRS Notice 2022-36, the IRS granted relief from certain failure-to-file penalties and certain international information return penalties for most individual and business taxpayers who did not file…

IRS’ Takes Legal Action Against Offshore HSBC Indian Accounts

- By : Parag Patel

…year over six years. HSBC will likely cooperate with the IRS and release all Indian American account holders’ names for which the IRS is seeking information, much like UBS did…

An Ill-advised IRS Streamlined Filing Compliance Procedure Filing

- By : Parag Patel

Yesterday the US Department of Justice announced here the indictment of Mark Anthony Gyetvay, who filed to enter IRS “Streamlined Filing Compliance Procedures in which he attested that his prior…

IRS Publishes Useful Chart Outlining Compliance Options for Offshore Assets

- By : Parag Patel

The IRS has recently published a useful chart outlining options available to help US taxpayers with offshore interests. The new IRS chart correctly states that it “recognizes that its focus…

Do You Have to Pay US Taxes on Foreign Inheritance?

- By : Parag Patel

…on foreign inheritance to the IRS? No, the IRS does not impose taxes on foreign inheritance or gifts if the recipient is a U.S. citizen or resident alien. Although the…

New offshore account disclosure law

- By : Parag Patel

…a charitable trust) IRS may treat the trust as having a U.S. beneficiary unless such person can demonstrate to the satisfaction of IRS that under the terms of the trust,…

2016 US Dept of Justice (DOJ) Tax Division: FBAR penalty collection cases

- By : Parag Patel

…enforced collection would require a lawsuit in federal court. This limitation on the IRS’s ability to administratively collect the FBAR penalty should provide an inducement to the IRS to resolve…

Federal District Court Holds that FBAR Penalties in Excess of $100,000 is Unlawful

- By : Parag Patel

…criminal sanctions may outweigh this dollar issue. See OVDP FAQ 6 ). Finally, unless the IRS appeals and wins the case, it seems to me that until appropriate action is…

ERC Disallowance Letters 105C Sent to Taxpayers

- By : Parag Patel

The IRS has notified over 20,000 taxpayers via IRS Letter 105C (Disallowance of Claim) that their claims for the employee retention credit are being disallowed because entities either did not…

How to Avoid Jail and Clean Up Tax Problems

- By : Parag Patel

…sent to the examination for review and examination. The taxpayer must cooperate with the IRS examiner or else the examiner can request that the IRS revoke its acceptance of the…